The unveiling of the EU tax haven blacklist was covered in our Alert dated 12 December, 2017. While the consequences of a jurisdiction being on the blacklist remain largely unclear, clients may wish to review whether they have transactions
Disputing Tax
Quarterly Insights from Ropes & Gray
Disputing Tax, published by Ropes & Gray, focuses on legal issues related to tax controversies and disputes. The blog covers topics such as tax litigation, IRS enforcement, tax settlements, and regulatory developments affecting taxpayers and tax professionals. It also addresses emerging areas like digital asset taxation, international tax compliance, and the impact of new tax legislation and directives on various industries, including private equity and retirement plans. The blog provides analysis of court decisions, government policies, and tax authority guidance relevant to tax dispute resolution and compliance strategies.
Latest from Disputing Tax - Page 13
New Partnership Audit Regulations Released as Permitting Push-Out Election Through Tiered Partnerships
By Kat Gregor & Denise Sohn
In a trilogy of releases in the last six weeks, the Department of Treasury (“Treasury”) provided much-needed guidance on the implementation of the partnership audit rules in the Bipartisan Budget Act of 2015 (the “BBA Rules”). On the eve of…
Delaware Chancery Court Rules that Buyer is Not Entitled to Share in Transaction Tax Deductions
On December 29, 2017, the Delaware Chancery Court decided in LSVC Holdings, LLC. v. Vestcom Parent Holdings, Inc. et al. to deny the buyer’s claim for an allocated share of transaction tax deductions (“TTDs”) taken by the seller in a…
Tax Reform Act Doubles Gift, Estate and GST Tax Exemptions
Congress has passed and President Trump has signed new tax reform legislation (the “Act”). Although the Act falls short of repealing the “death tax”, it doubles the amount an individual may transfer free of tax either by gift during lifetime…
Tax Reform: Key Provisions for Tax-Exempt Organizations
By Kendi Ozmon & Gil Ghatan
After much uncertainty surrounding competing bills, the House of Representatives voted to pass comprehensive tax reform legislation (the “Act”) on December 20, 2017, shortly after the Senate passed the measure. The Act will now be sent to President Trump’s desk,…
Tax Reform: Deductibility of Government Payments Materially Limited
By Kat Gregor
On Wednesday, December 20, 2017, the House of Representatives and Senate passed comprehensive tax reform legislation. The bill, which is expected to be signed by President Trump in the coming weeks, amends the tax treatment of payments made to (or…
Congress Sends Tax Reform Bill to President for Signature
On Wednesday, December 20, 2017, the House of Representatives voted to pass the most significant tax reform legislation in three decades (the “Act”) just hours after the Senate passed the measure. The legislation’s provisions will affect a broad range of…
New Partnership Audit Regulations Released as Effective Date Draws Near
By Kat Gregor & Denise Sohn
On November 29, 2017, the Department of Treasury (“Treasury”) issued proposed regulations (REG-119337-17) addressing certain international tax aspects of the centralized partnership audit regime passed into law in the Bipartisan Budget Act of 2015 (the “BBA Rules”). The newly proposed…
EU Blacklisting of Tax Havens
By Amanda Raad & Jo Torode
After months of screening global tax policies by the European Council’s Code of Conduct Group, the EU has finalised its tax-haven blacklist – a list of non-cooperative jurisdictions for tax purposes, which currently comprises the following 17 jurisdictions: American Samoa,…
‘Willfulness’ In Civil FBAR Cases Comes Down To The Facts
By Kat Gregor
In a recent Law360 article, “‘Willfulness’ In Civil FBAR Cases Comes Down To The Facts,” Kat Gregor commented on a recent court decision allowing a pharmaceutical company CEO to escape civil penalties for failing to report his Swiss bank account…