Greg Armstrong

Greg Armstrong is a director in the Practice, Procedure, and Administration group of KPMG'e Washington National Tax Practice. He advises on procedural and administrative issues affecting IRS examination and collection matters, with a focus on the Bipartisan Budget Act (BBA) centralized partnership audit regime and the Tax Equity and Fiscal Responsibility Act (TEFRA) partnership audit procedures. He also advices on statutes of limitation, the mitigation provisions, and late election relief.

Greg joined KPMG Washington National Tax from the IRS Office of Chief Counsel in Washington, DC. He worked at IRS for almost 10 years, mainly with the Office of Associate Chief Counsel (Procedure & Administration) where he started as an attorney and eventually was promoted to Senior Technician Reviewer. Greg also briefly worked with the Office of Associate Chief Counsel (International).  Prior to his departure from IRS, Greg was the lead manager on IRS Counsel’s implementation of the BBA centralized partnership audit regime.  

Greg’s efforts on the BBA project helped Treasury and the IRS publish several pieces of guidance, including temporary, proposed, and final regulations. For example, in August 2018 under Greg’s leadership the IRS published final regulations governing the election into the BBA regime and the designation and authority of the partnership representative.  In December 2018, Greg helped shepherd the release of comprehensive final regulations providing rules for assessment, collection, penalties, interest, and statutes of limitation under the BBA regime. Greg also assisted in developing draft forms and instructions and other forms of IRS guidance. 

Prior to his work on the BBA, Greg authored Revenue Procedure 2014-55, Election Procedures and Information Reporting with Respect to Interests in Certain Canadian Retirement Plans, and drafted proposed regulations under section 6109 regarding EINs and responsible parties.  Earlier in his career, Greg litigated cases in the U.S. Tax Court and assisted the Department of Justice on disputes involving the TEFRA procedures, judicial doctrines, IRS summonses, and the Freedom of Information Act. 

In the past, Greg has co-taught courses on professional responsibilities of tax practitioners, legal writing, and corporate tax for Villanova University’s online Graduate Tax Program.  Greg is also a contributing editor to the leading treatise on IRS procedural matters — Saltzman and Book, IRS Practice and Procedure.