Please refer to the following list of recent tax and tax controversy-related COVID-19 alerts in addition to original articles for insight and guidance pertaining to updates from the Biden Administration. For a comprehensive list of related thought leadership, please refer to the COVID-19 landing page.
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In Bloomberg Tax, tax associates Isabelle Farrar, Alec Oveis, Phillip Popkin, and Joshua Thomas evaluate new IRS guidance regarding employee retention credits which are included in various legislative pandemic relief packages. The tax attorneys summarize the IRS notices, explaining guidance on how businesses can simultaneously take advantage of both Paycheck Protection Program (PPP) loans and…
On September 3, the Department of the Treasury issued final regulations regarding the base erosion and anti-abuse tax (“BEAT”) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties.[1] The final regulations provide guidance on a number of areas, an important section of the regulations pertains to the…
The IRS has been closely scrutinizing syndicated conservation easements since December 2017. In 2020, there have been some important developments in this area. First, in June 2020 the IRS announced a time-limited settlement opportunity for certain docketed Tax Court cases. Second, in August and September 2020, the Senate Finance Committee issued a report and data…
In this Ropes & Gray podcast, Isabelle Farrar, an associate in the tax controversy group, is joined by Elizabeth Smith, counsel in the tax controversy group, and Jennifer Romig, a partner in the health care group, to discuss the state taxation of digital products, an evolving area in several states. Specifically, they will discuss…
In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states’ taxing authority. In a February decision, Dawson v. Steager, the Court held that a state cannot tax a federal retiree’s pension benefits while declining to tax a similarly situated state retiree. The March decision in BNSF…
On December 21, 2018, IRS and Treasury issued final regulations implementing the partnership audit regime (T.D. 9844). The final regulations largely adopt, with some changes, the proposed regulations issued in August 2018. By issuing almost 200 pages of preamble, the final regulations provide extensive discussion of which comments were incorporated and why others were…
On November 20, 2018, IRS issued a memo on its new voluntary disclosure program (“Voluntary Disclosure Program” or “Program”), following the offshore voluntary disclosure program’s termination on September 28, 2018. The Voluntary Disclosure Program provides taxpayers with a process for voluntarily disclosing tax noncompliance for both domestic and offshore assets to avoid potential criminal liability…
On December 13, 2018, the IRS published proposed regulations (REG-104259-18) on the Base Erosion and Anti-Abuse Tax (the “BEAT”), a new tax regime under the Tax Cuts and Jobs Act (“TCJA”). BEAT is designed to discourage multinational corporations from profit-shifting behavior by making deductible payments to their foreign affiliates, such as interest, high-margin service payments,…
The Internal Revenue Service (IRS) and other global taxing authorities are continuing to focus on bringing taxpayers who hold cryptocurrencies into compliance.
As cryptocurrencies have made some investors very wealthy, concern has arisen that investors are not reporting gains to taxing authorities. Internationally, governments are committed to bringing these investors into compliance. The most important…
