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We are pleased to enclose the June issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting Retirement Relief Provisions Accessible to More Taxpayers and Recent California State and Local Tax Developments.

In this issue:

      • Legislative and Regulatory Update:Should We Brace Ourselves For a Busy August?
      • Tax Court Agrees that Settlement Payment is Sale of Partnership Interest and Not Lost Profits
      • Rev. Proc. 2020-34: Relief for DSTs Amid the COVID-19 Pandemic
      • Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting
      • Retirement Relief Provisions Accessible to More Taxpayers
      • Cameco Corporation: Recharacterization Does Not Mean Ignoring Transactions as Structured by the Taxpayer
      • New Mandatory Disclosure Rules in Mexico – “Reportable Schemes”
      • High Net Worth Taxpayers FaceIRS Wealth Squad
      • A “Manufactured” Attack: Department Takes Aim at Contract Manufacturing and Redrafts the Tax Law in New Draft Regulations
      • Recent California State and Local Tax Developments
      • Canada Emergency Wage Subsidy(CEWS) Extension
      • DAC6 Update
Author

Alexandra Minkovich is a partner in Baker McKenzie's North American Tax Practice. She has over a decade of experience handling a variety of tax, tax controversy and legislative issues. She also brings significant experience representing clients with respect to domestic tax issues, including advising financial institutions, and is well versed in administrative law. Immediately prior to joining the Firm, Ms. Minkovich served as Associate Tax Legislative Counsel with the U.S. Department of Treasury, Office of Tax Policy. In that role, Ms. Minkovich advised the Assistant Secretary (Tax Policy) and General Counsel regarding tax policy considerations in regulations and Internal Revenue Bulletin guidance, provided advice on tax legislative proposals, and provided litigation advice regarding the validity of Treasury and IRS guidance. She also provided technical comments on tax legislation to the Senate Committee on Finance and the House Ways & Means Committee, as well as to individual members’ offices.

Author

Joshua D. Odintz is a partner in and on the management committee of Baker McKenzie’s North American Tax Practice Group. Joshua held high-level government positions with both the US Department of the Treasury and the Senate Finance Committee. He previously served as a Senior Advisor for Tax Reform to the Assistant Secretary at the US Department of the Treasury, where he advised Senior Treasury officials on tax reform options and issues. Joshua also served as the Chief Tax Counsel to the President’s National Commission on Fiscal Responsibility and Reform, and was instrumental in formulating the tax proposals that were contained in the Commission’s report, entitled the Moment of Truth. Additionally, Joshua served as the Acting Tax Legislative Counsel at the Treasury. Joshua is a frequent speaker at IFA, TEI, ABA Tax Section, NY State Bar Tax Section, Practicing Law Institute and Federal Bar Association tax meetings and conferences.

Author

Christopher H. Hanna joined Baker McKenzie as Counsel in January 2019. He is the Alan D. Feld Endowed Professor of Law and the Altshuler Distinguished Teaching Professor at Southern Methodist University. Professor Hanna has been a visiting professor at the University of Texas School of Law, the University of Florida College of Law, the University of Tokyo School of Law and a visiting scholar at the Harvard Law School and the Japanese Ministry of Finance. In 1998, Professor Hanna served as a consultant in residence to the Organisation for Economic Co-operation and Development (OECD) in Paris. From June 2000 until April 2001, he assisted the US Joint Committee on Taxation in its complexity study of the US tax system and, from May 2002 until February 2003, he assisted the Joint Committee in its study of Enron, and upon completion of the study, continued to serve as a consultant to the Joint Committee on tax legislation. From May 2011 until December 31, 2018, he served as Senior Policy Advisor for Tax Reform (Republican staff) to the United States Senate Committee on Finance, working extensively on the Tax Cuts and Jobs Act of 2017.

Author

Sukbae David Gong is an associate in Baker McKenzie’s Global Tax Practice Group in Chicago. He provides domestic and international tax planning advice for corporations and pass-through entities. Prior to law school, he was an auditor at a Big Four accounting firm working on financial statement audits of various public and private companies. He passed the CPA exam in 2009. He was also a sergeant in the Republic of Korea Army.

Author

Peter Matejcak is a partner in the Firm's Global Tax Practice Group in the Chicago office. Peter advises on US federal income tax issues and provides tax structuring advice to US and foreign taxpayers. Prior to attending law school, Peter worked at a Big Four public accounting firm, providing tax compliance and planning services to private and middle-market companies and their owners. He is a regular contributor to Real Estate Taxation and the Journal of Passthrough Entities as a REIT columnist, and is the co-author of the Taxation of Securities Transactions treatise. He is also a Certified Public Accountant and an adjunct professor at Northwestern University School of Law and DePaul University College of Law, teaching the Taxation of Structured Real Estate Transactions.

Author

Christopher (Chris) S. Raybould is the Canadian Transfer Pricing Practice Leader and Director of Economics for Baker McKenzie in Toronto and previously served as a member of the firm’s North American Transfer Pricing Steering Committee. Mr. Raybould handles transfer pricing advisory work in various capacities. He advises on and assists in negotiating advance pricing arrangements, pursuing competent authority assistance, provides audit defense representation, appeals support, and Transfer Pricing Review Committee representation. He also advises on a variety of other types of transfer pricing projects, including BEPS related advice, risk identification and assessment, planning and compliance studies, and assists with the transfer pricing aspects of business conversions and restructurings, acquisition due diligence and integration. Mr. Raybould has extensive experience in a number of industry sectors including automotive, pharmaceutical, food, financial investments and products, manufacturing, consumer businesses, technology, and commodity-based businesses. Mr. Raybould is an author on transfer pricing issues and a frequent speaker.

Author

Nicholas Serra is an associate in Baker McKenzie's Global Tax Practice Group in Chicago. He provides domestic and international tax planning advice for corporations and pass-through entities.

Author

Christine M. Kim is an associate in Baker McKenzie’s Tax Practice Group. She focuses on tax controversy, transfer pricing, and tax planning.

Author

Alex is a partner in Baker McKenzie’s Tax Practice Group in Toronto with over 20 years of experience. He is both a lawyer and a Chartered Professional Accountant.

Author

Jorge Narváez-Hasfura is a partner in Baker McKenzie's Mexico office. With 32 years of experience, he has been voted as a leading tax practitioner in Mexico on tax litigation, transfer pricing and indirect taxation by the International Tax Review. He has been nominated to appear in the Guide to the World's Leading Transfer Pricing Advisers. He has been voted as one of the leading tax practitioners in Mexico by Chambers & Partners every year since 2011, and praised by well-known international publications for his transfer pricing and corporate reorganization work alongside his very strong practice in tax rulings, treaties and litigation.

Author

Javier Ordoñez-Namihira joined Baker McKenzie, Mexico City in 2004. He currently practices as a partner in the Tax group. He is the author of various articles published in Tax Notes International and Practical Mexican Tax Strategies magazine from Thomson Reuters, as well as a frequent speaker at national and international seminars such as Baker McKenzie’s 17th Annual Tax & Trust Training Program in Miami and the Bermuda Captive Conference, both held in 2015.

Author

Juan Carlos Valles is a Partner from the Tax Practice Group and regularly advises clients in the areas of international tax planning, permanent establishment, taxation of non-residents, cross-border transactions, corporate taxes, flat tax and value added tax. Valles previously work as a member of the Firm’s Foreign Trade and Customs Practice Group for several years, where he assisted several companies with legal advice on Mexico’s network of free trade agreements and other legal matters related to the international trade regulation and customs legislation.

Author

Paul DePasquale is a partner in Baker McKenzie's Tax and Global Wealth Management practice groups in New York. He advises individuals and multinational entities on international and domestic tax planning, cross-border transactions and investments, and wealth management. He also advises financial institutions on regulatory, compliance and strategy matters. Paul previously worked in the Firm's Zurich and Hong Kong offices. He is a frequent speaker and writer on international tax compliance and information reporting.

Author

Nicole (Niki) Ford is a member of Baker McKenzie’s Tax Practice Group in New York where she focuses on state and local tax litigation and planning. Prior to joining the Firm, Niki was a state and local tax associate in an international law firm.

Author

Mike Shaikh is a partner in the Tax Group of Baker McKenzie's Los Angeles office. He practices exclusively in state and local tax on California and multistate tax controversy and planning.

Author

Stephanie's practice focuses on the Canadian tax aspects of corporate mergers, acquisitions, divestitures, reorganizations, financings and other tax planning in both the international and domestic contexts. Stephanie has particular experience advising on Canadian tax issues affecting multinationals with operations in Canada, including inbound structuring, cross-border employee mobility, withholding tax, and tax treaty issues, and on matters relating to executive compensation. Stephanie has industry specific experience in sectors including technology, media and telecommunications, energy, mining and infrastructure, and consumer goods and retail.

Author

Mounia Benabdallah is a partner in Baker McKenzie’s International Tax Practice Group. She joined Baker McKenzie in 2006 and has practiced in the Firm’s offices in Amsterdam, Chicago and New York. As an attorney at law she is admitted to the Netherlands Bar. Mounia is repeatedly recognized as leading advisor in ITR’s Women in Tax Leaders guide. Because of her strong US focus, Mounia is based in New York and member of the Global Reorganizations Practice Group. Mounia mainly advises US multinationals on the interplay between US international tax law, European tax law and Netherlands tax law in global restructuring projects, with a strong focus on global (OECD BEPS) and European tax policy developments.

Author

Megan Ruigrok is an associate in Baker McKenzie’s Amsterdam office. She is experienced in corporate tax law, international tax law, tax planning and tax dispute resolution.