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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…

Niles A. Elber, H. David Rosenbloom, Charles M. Ruchelman, Heather D. Schafroth, Ross R. Sharkey

Reverse Claw-Backs Revisited: IRS Issues Post-Altera Guidance on Adjustments for Stock-Based Compensation Costs and Cost Sharing Arrangements

USA - July 22 2021 An IRS Office of Chief Counsel memorandum released July 16, 202 provides a roadmap for IRS transfer pricing Examinations involving cost sharing…

Heather D. Schafroth, Elizabeth J. Stevens

Biden’s Proposed Tax Increases - How Do they Affect Bona Fide Residents of Puerto Rico?

OECD, Puerto Rico, USA - June 1 2021 The Biden Administration published its Green Book of tax proposals on May 28, 2021. The following is a brief summary of key provisions that we think…

Alert: Is an Act /60 Taxpayer Required to Have a Transfer Pricing Study?

USA - April 28 2021 No. The IRS does not require any taxpayer to develop a transfer pricing study. The real question is “what Would a transfer pricing study do for me?”…

Alert: IRS to “Campaign” into Puerto Rico; How can Taxpayers Defend?

Puerto Rico, USA - February 3 2021 The IRS has announced a new "Campaign." It will focus its attention on U.S. persons who have reduced their U.S. tax burden by claiming benefits…

Tom Duffy, Dianne C. Mehany, Amanda Reed