Recent Developments Affecting Taxpayers and their Representatives

A panel from Orrick's Tax Advocacy Group will discuss hot-button issues for tax practitioners and their clients, including whether to classify workers as employees or independent contractors, transfer pricing, and recent litigation over FBAR penalties.

Topics will include:

• Employee v. Independent Contractor Tax Issues
• Transfer Pricing Update
  • What is the state of deference to Treasury’s tax regulations following the Ninth Circuit’s decision in Altera?
  • What does the Ninth Circuit's recent Multinational Tech Company (U.S.) decision about the meaning of "intangibles" mean for major transfer pricing disputes going forward?
  • What impact will Altera and Multinational Tech Company (U.S.) have on company financial statements?
• Recent Tax Cases
  • How will recent appellate decisions regarding which company is entitled to a tax refund following bankruptcy of a corporate parent affect tax sharing agreements?
  • How will the application of multiple FBAR penalties affect future IRS settlements?
• Taxpayer First Act of 2019
  • How will this affect tax controversies and whistleblower claims?

The panelists are members of Orrick's Tax Advocacy Group who have decades of experience representing taxpayers and accountants in all phases of civil and criminal tax litigation, including audits, investigations, trials and appeals.

The panel discussion will take place in our San Francisco office (with registration at 8:30 am PST), and will also be available as an online webinar.