Kat Saunders Gregor

Partner

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  • JD, cum laude, Harvard Law School, 2005
  • BS (Accounting), magna cum laude, Georgetown University, 2000

Qualifications

  • England and Wales, Solicitor, 2009
  • New York, 2006
  • Massachusetts, 2006

Court Admissions

  • U.S. Court of Appeals for the Federal Circuit, 2008
  • U.S. Tax Court, 2008
  • U.S. Court of Federal Claims, 2006
  • Member, Tax Editorial Board, Law360 (2018-2019)
  • Member, Tax Authority Federal Editorial Board, Law360 (2019)
  • Boston Business Journal 40 Under 40 (2016)
  • Massachusetts Super Lawyers Rising Star (2013-2017)

Kat Saunders Gregor

Partner

Kat is a tax partner and co-founder of the Tax Controversy Group. Kat regularly handles disputes with the IRS, DOL and other administrative bodies, and assists clients in managing disputes with non-U.S. tax authorities. Kat represents public companies, private investment funds, institutional investors, private companies and high net worth individuals before the U.S. Tax Court, U.S. Court of Federal Claims and other federal and state courts.

Kat’s practice encompasses a wide range of partnership and international tax issues, with a focus on the asset management and life sciences industries. Kat advises private investment fund managers on structuring and launching funds, and has worked extensively on fund investment and secondary transactions. She regularly assists life sciences companies in evaluating ongoing tax issues arising from international growth, development and implementation of new technology and products and formation and management of joint ventures. She also represents public and private clients in ongoing tax issues, as well as merger, acquisition and restructuring transactions.

Kat previously practiced as a CPA with PricewaterhouseCoopers LLP, where she advised venture capital funds and their portfolio companies on tax compliance, planning, and controversy matters.

Experience

Tax Controversies and Disputes

  • Representing a multinational travel and tour operator in a dispute with the IRS regarding the application of subpart F and Section 1248 to a foreign subsidiary (currently pending before IRS Office of Appeals).
  • Representing a large hedge fund in ongoing proceedings in the U.S. Court of Federal Claims, the U.S. Tax Court and the Court of Appeals for the Federal Circuit.
  • Representing multiple asset management clients in examinations by the IRS regarding the tax treatment of management fees (including several successful resolutions at the examination and IRS appeals stages). 
  • Lead counsel in Veolia Energy Boston v. Board of Assessors of Boston, argued before the Massachusetts Supreme Judicial Court (SJC-12634, under advisement).
  • Lead counsel representing a multinational energy company before the Massachusetts Appellate Tax Board, achieving a complete victory in a multi-million dollar dispute over whether the company is properly classified as a manufacturing corporation.
  • Representing multiple clients in the asset management, life sciences and medical industry in routine ERISA examinations by the DOL.
  • Represented the founder of a successful pharmaceutical company in a dispute with the IRS regarding the valuation of transfers of stock to estate planning vehicles.
  • Lead counsel for a charitable estate in a U.S. Tax Court dispute regarding the decedent’s taxable income, achieving a favorable resolution through a referral to the IRS Appeals Office.
  • Representing several pharmaceutical and medical device companies in IRS examinations following regulatory settlements with the FDA, DOJ and SEC.
  • Represented the U.S. subsidiary of a multi-national software company regarding an ongoing dispute with the IRS regarding intercompany transfer pricing arrangements.
  • Represented a film production company in an IRS appeal regarding significant personal holding company issues.
  • Represented a large U.S.-based software company in an IRS appeal regarding the deductibility of management fees paid to private equity sponsors; currently representing several portfolio companies in similar disputes at the IRS examinations level.

Tax Advice and Planning

  • Represent asset management clients in the formation of new funds and ongoing operational matters, including Pacific Equity Partners, Gauge Capital, Moelis Capital Partners, Bain Capital and GMO.
  • Advise various institutional investors in investments in private equity, hedge and other alternative assets investment funds, including with the ongoing implementation of U.S. tax reform and implementation of the OECD BEPs initiatives to existing and new investment structures.
  • Advise hospitals, pharmaceutical and medical device manufacturers in ongoing planning for joint ventures and international expansion.
  • Advise investors and asset managers on alternative investments in the energy, commodity, blockchain and cryptocurrency and other emerging or frontier markets, with a particular focus on the use of cross-border partnerships and investment vehicles.
  • Advise multinational clients in the asset management, life sciences and emerging markets industries on global changes to transfer pricing, anti-abuse and tax treaty principles.

Publications

Presentations

  • Panelist, “Hidden Wealth: The Global Campaign for Tax Transparency – the Latin Response,” 12th Annual Tax Planning Strategies - U.S. and Latin America Conference (June 2019)
  • Panelist, “I'm a US Lawyer, What's the EU Got To Do With Me? – Navigating Ethics in Global Practice,” ABA Tax Section 2019 Midyear Tax Meeting (January 2019)
  • Panelist, “Update on the Implementation of BEPS-inspired anti-avoidance measures,” IBA Conference 2018 (October 2018)
  • Panelist, “Interesting Partnership Transactions,” Practicing Law Institute's Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2018 (June and May 2018)
  • Moderator, “Administrative Practice Committee Important Developments,” ABA Section of Taxation May Meeting (May 2018)
  • Panelist,  “Transfer Pricing Controversy,” New England Regional IFA Conference (November 2017) 
  • Panelist, “Export Forum – Resolving Tax Disputes with Regulators,” Corporate Disputes (July-September 2017)
  • Panelist, “The Private Investment Fund Tax Master Class: Impact of the New Partnership Audit Rules: Going Beyond the Mechanics,” Financial Research Associates (May 2016)
  • Panelist, “New IRS Partnership Audit Regulations: What Every Tax Adviser Needs to Know: Planning Tools to Prepare for Massive Changes Ahead,” Strafford Webinar (May 2016)
  • Panelist, “Tax Strategies for Limited Partner Investors in Private Investment Funds: Avoiding Tax Traps Through Side Letters and Other ‘Hidden’ Agreements,” Strafford Webinar (April 2016)
  • Panelist, “Tax Court 101: Everything You Wanted to Know About Litigating Tax Cases,” American Bar Association, Tax Section Midyear Meeting (2016)
  • Panelist, “Tax Opinions, Privilege and Waiver,” International Fiscal Association, New England Branch Conference (2015)
  • Panelist, “IRS Audit Guide: What to Expect if/when the IRS Pays a Visit,” 17th Annual Effective Hedge Fund Tax Practices, Financial Research Associates (November 2015)
  • Panelist, “Tax Disputes in the US,” Corporate Disputes (2014)

Disclaimer

Ropes & Gray International LLP is a limited liability partnership registered in Delaware, United States of America and is a recognised body regulated by the Solicitors Regulation Authority (with registered number 521000).
  • JD, cum laude, Harvard Law School, 2005
  • BS (Accounting), magna cum laude, Georgetown University, 2000
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