During the January 2019 ABA Tax Section 2019 Midyear Tax
Meeting, Kat Gregor, tax partner and co-founder of the tax
controversy group, discussed the new EU mandatory disclosure rules
(known as DAC6 related to aggressive tax positions) and the ethical
obligations of U.S. attorneys to adhere to these rules. Kat noted
that "the EU rules are, on the one hand, trying to be more
precise as to what they're interested in catching, rather than
in the U.S., where they say any transaction over a certain dollar
value has to get reported. But on the flip side, it's going to
be really difficult for people to make the judgment call on whether
or not something falls in."
To read the full article with more insights from Kat, please
click here.