Disputing Tax

In this episode of Ropes & Gray’s podcast series Disputing Tax, Isabelle Farrar, an associate in the tax controversy group, is joined by Kat Gregor, a tax partner and tax controversy group co-founder, and Elizabeth Smith, counsel in the tax controversy group, to examine some potential areas of focus for IRS enforcement efforts in 2021.

In this episode of Ropes & Gray’s podcast series, Disputing Tax, Pascal Mayer, a senior attorney in the employment, executive compensation & employee benefits group, is joined by Kat Gregor and Loretta Richard, partners in the tax, employment & benefits practice and co-founders of the tax controversy group, to discuss the payroll tax provisions of the Coronavirus Aid, Relief and Economic Act (also known as the CARES Act) and factors that employers should consider in their coronavirus response. Enacted on March 27, and commonly referred to as “Phase 3” of the federal government’s response to the coronavirus pandemic, the CARES Act provides immediate financial relief to eligible employers by allowing them to retain some payments that would otherwise be owed to the federal government, through employee retention credits and deferral of the employer portion of social security tax payments. This assistance may be critically important to employers who are struggling to meet costs when faced with diminishing revenues or who had their operations fully or partially suspended due to governmental orders.

Description: In this Ropes & Gray podcast, Elizabeth Smith, counsel in the tax controversy group, is joined by David Saltzman, a partner in the tax group, to discuss the recent Tax Court memorandum decision, Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue. This case involved a strategy designed to permit a U.S. multinational to repatriate cash from its foreign subsidiaries without incurring current U.S. federal income tax.

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 how new technologies are rapidly shifting the delivery of health products and services, and how these new technologies are creating uncertainties in the sales and use tax world.

In this Ropes & Gray podcast, Isabelle Farrar, a senior associate in the tax controversy group is joined by Harvey Cotton, a principal in the tax and benefits group, and Elizabeth Smith, counsel in the tax controversy group, to discuss the December 2018 decision from the Northern District of Texas in Texas v. United States. This case deals with the constitutionality of the Individual Mandate in the Patient Protection and Affordable Care Act.

In this Ropes & Gray podcast, Alec Oveis, an associate in the tax and benefits group is joined by Kat Gregor, a partner in the tax group and co-founder of the tax controversy group, and Andy Howard, a partner in the tax group, to discuss the investigations now underway in Europe involving so-called “cum-ex dividend trades.”

Isabelle Farrar, a senior associate in the Tax Controversy Group discusses one of the most notable decisions of third quarter 2017, Grecian Magnesite Mining v Commissioner of Internal Revenue, with Rom Watson, a partner in the Tax Group and co-head of the firm’s International practice group. Grecian Magnesite Mining considered whether a foreign corporation’s proceeds arising from the redemption of an interest in a U.S.-based partnership were taxable in the U.S. as U.S.-source income or income effectively connected with a U.S. trade or business (ECI). In doing so, the Tax Court called into question the validity a 30-year old revenue ruling.

In this Ropes & Gray podcast, Brittany Cvetanovich, an associate in the tax group, is joined by Kat Gregor, tax partner and co-founder of the tax controversy group, to discuss a notable Supreme Court decision, South Dakota v. Wayfair. On June 21, 2018, the Supreme Court ruled in Wayfair that the State of South Dakota may constitutionally require large online retailers without actual physical presence in the state to collect and remit sales tax.

In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for taxpayers, particularly multinational corporations. On September 29, 2017, in Chamber of Commerce of the United States of America et al v. Internal Revenue Service et al, the U.S. District Court for the Western District of Texas held that the Internal Revenue Service and the U.S. Treasury Department violated the Administrative Procedures Act by issuing an anti-inversion rule, specifically the “Multiple Domestic Entity Acquisition Rule,” saying it was unlawfully implemented without giving the public enough notice or time to comment.