Kat Saunders Gregor

Partner

gregor-kathleen-saunders

Contact

  • 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
  • U.S. District Court for the Southern District of New York, 2019
  • Fellow, American College of Tax Counsel 
  • Co-Chair, Annual U.S. and Europe Tax Practice Trends Conference 
  • Member, Tax Authority International Editorial Advisory Board, Law360 (2021) 
  • Member, Tax Editorial Advisory Board, Law360 (2018-2020)
  • Officer, Taxes Committee, International Bar Association (2020-2021)
  • Trustee of the Massachusetts Taxpayers Foundation
  • The Best Lawyers in America (2022)
  • Chambers USA: America's Leading Lawyers for Business (2021)
  • Boston Business Journal 40 Under 40 (2016)
  • Massachusetts Super Lawyers Rising Star (2013-2019)

Kat Saunders Gregor

Partner

Kat Gregor is a tax partner who advises on a wide range of partnership and international tax issues, with a focus on the asset management industry. Kat advises private investment fund managers on structuring and launching funds, and has worked extensively on fund investment and secondary transactions. She also advises institutional investors on investments into private funds, international joint ventures and strategic investments across industries, including health care, natural resources, real estate and emerging technologies. As part of her asset management-related work, Kat advises family offices on their structure, ongoing operations and investments.

In addition to her work for asset management clients, Kat regularly assists life sciences, FinTech and growth companies in evaluating ongoing tax issues arising from international operations, new technology and products, and the formation and management of joint ventures. Throughout the COVID-19 outbreak, she also helped clients navigate key tax-related provisions of the CARES Act and other emergency legislation.

A co-founder of the tax controversy group at Ropes & Gray, Kat is known for handling disputes for clients with the IRS, DOL and other administrative bodies, and in particular, represents asset management firms, including their principals and portfolio companies. She also assists clients in managing disputes with non-U.S. tax authorities, bringing the critical ability to explain complex cross-border investment structures. Clients commend her for her “expertise in the nooks and crannies of controversy work,” as noted in Chambers USA, where she is ranked. Kat represents public and private companies, private investment funds, institutional investors and high-net-worth individuals before the U.S. Tax Court, the U.S. Court of Federal Claims, and other federal and state courts.

Drawing in part on her prior experience as a CPA with PricewaterhouseCoopers LLP, Kat advises clients on the state and local tax impact of their operations and investments. This work includes representing clients before administrative bodies, seeking rulings and other guidance, and resolving historic noncompliance. Kat works closely with clients’ accountants and local advisors to develop strategies for multistate tax issues and to resolve issues and disputes efficiently.

Kat is active in the legal and tax communities in both the United States and globally, and is a frequent writer and commentator on tax issues. She serves as a co-chair of the Tax Working Group of the Law Firm Antiracism Alliance. She also is an executive officer of the International Bar Association Taxes Committee, the Northeast Regional Chair of the Women International Fiscal Association Network (or WIN-IFA), and a co-chair of the annual U.S.-Europe Tax Practice Trends Conference.

Experience

Tax Controversies and Disputes

  • Successfully argued before the Massachusetts Supreme Judicial Court to obtain a unanimous decision in client's favor upholding a multimillion dollar property tax exemption. (Veolia Energy Boston v. Board of Assessors of Boston (SJC-12634, 2019)).
  • Successfully defended several high net worth individual clients before administrative disputes regarding state examinations of their residency and domicile, including inquiries by New York, Massachusetts and Connecticut.
  • 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 representing the taxpayer corporation in a full victory regarding the taxpayer’s status as a manufacturing corporation in Massachusetts before the Massachusetts Appellate Tax Board (Board of Assessors of the City of Boston v. Commissioner of Revenue and Veolia Energy Boston, ATB Docket No. C331142, 2019).
  • 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 investments in the energy, commodity, real estate, blockchain, cryptocurrency and other emerging or frontier markets, focusing on the use of cross-border 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, “State Tax Considerations for Remote Workforces" New England SALT Forum (November 2021)
  • Panelist, “Update on LB&I Campaigns: Hear the Latest from the IRS,” WIN-IFA Webinar (Augusts 10, 2021) 
  • Co-chair, “Digital Economy – OECD Pillar 1 & 2 Developments & the LATAM Digital Taxes in Practice,” U.S. and Latin America Tax Practice Trends (June 2021) 
  • Speaker, “Tax Open Forum Discussion: what next for Pillar One?,” IBA Taxes Committee Webinar (March 30, 2021) 
  • Co-chair, “New Transfer Pricing Developments: 2020 Key Cases and Pandemic Impact,” Virtual 21st Annual U.S. and Europe Tax Practice Trends Conference (March 2021)
  • Co-panelist, “Preserving Privilege in a Virtual World,” Virtual TEI Midyear Meeting (March 2021)
  • Co-presenter, “Tax Disputes Landscape—MAP & APA,” A&L Goodbody and Ropes & Gray Joint Webinar (March 3, 2021)
  • Panelist, “International Tax Controversy Panel (LB&I),” IFA USA International Tax Conference: The Tax Cuts and Jobs Act - A Three-Year Review (December 2020) 
  • Presenter, “Tax Audits and Litigation Series: A Closer Look at 965 Campaigns”, Tax Audits and Litigation Committee of the D.C. Bar Taxation Community (December 2020)  
  • Co-panelist, “Apparent Transparency: BEPS Actions 12 & 13,” Virtual TEI Annual Conference (October 2020)
  • Keynote Speaker, “U.S. Tax System,” IFA Colombia Annual Summit (October 2020)
  • Co-panelist, “Changes in Taxes Ahead!,” Investment Advisor Association Leadership Week (October 2020)
  • Moderator, “Taxing Change: Challenges in the New Economy,” Virtual IBA New Era of Taxation Conference (September 2020)
  • Panelist, “DAC 6 - New Transparency Requirements in Europe,” Virtual 20th U.S. and Europe Tax Practice Trends Conference (June 2020)
  • Panelist, “Use of Dispute Resolution to Resolve Large, Complicated Corporate Tax Disputes,” Leading Women in Tax Forum (March 2020)
  • Panelist, "Navigating the MLI: The New International Tax and Investment Landscape,” ASIL Biennial International Economic Law Conference (February 2020)
  • Co-chair, “Hot Topics in U.S. Inbound and Outbound Investments,” The New Era of Taxation: What You Need to Know in a Constantly Changing World, IBA Conference (November 2019)
  • Panelist, “Rapid Fire Litigation Trends,” Massachusetts Taxpayers Foundation Annual Tax Policy Conference (October 2019) 
  • 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)
  • 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
  • U.S. District Court for the Southern District of New York, 2019
  • The Best Lawyers in America (2022)
  • Chambers USA: America's Leading Lawyers for Business (2021)
  • Boston Business Journal 40 Under 40 (2016)
  • Massachusetts Super Lawyers Rising Star (2013-2019)
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