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IRS “Dirty Dozen” List Includes “Potentially” Abusive Use of U.S.-Malta Tax Treaty in Pension Plans

Malta, USA - August 17 2021 The Internal Revenue Service (IRS) has placed certain Malta-based pension plan arrangements on its annual "Dirty Dozen" list of "tax scams." In its…

J. Clark Armitage, Niles A. Elber, Charles M. Ruchelman, Heather D. Schafroth, Ross R. Sharkey.

IRS Wins Big in The Coca-Cola Company & Subs. v. Commissioner

USA - November 23 2020 On November 18, 2020, the Tax Court ruled that respondent IRS had not abused its discretion under § 482 when it reallocated more than $9…

J. Clark Armitage, Kirsten Burmester, Heather D. Schafroth, Elizabeth J. Stevens.

CARES Act Offers Income Tax Relief for Business

USA - March 27 2020 On March 27, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was passed to stabilize the flagging U.S. economy. Among other measures…

J. Clark Armitage, Jonathan S. Brenner, Kirsten Burmester, James E. Salles, Elizabeth J. Stevens.

OECD Announces a Public Consultation for Global Minimum Tax Rules

Global, OECD - November 25 2019 On November 8, the OECD announced a Request for Comments and a December 9 public consultation on its Global Anti-Base Erosion (GloBE) proposal,…

J. Clark Armitage, Kirsten Burmester, Jaehong Lee, Elizabeth J. Stevens.

A Fragmenting OECD “Unified Approach” to Addressing the Challenges of the Digital Economy

OECD - October 11 2019 On October 9, the OECD announced its much-anticipated proposed “Unified Approach” to tackling tax challenges arising from the digitalization of the…

J. Clark Armitage, Kirsten Burmester, Jaehong Lee, Elizabeth J. Stevens.