The Internal Revenue Service (“IRS”) announced its plan to pursue criminal investigations into potential abuses of Puerto Rico’s Act 20/22/60 tax incentive programs. In a July 14, 2023, release, the IRS revealed that “[t]hanks to Inflation Reduction Act resources,” it has begun a criminal crackdown on Act 20/22/60 participants engaging in a ”[h]igh-dollar
In a case with far-reaching implications for tax jurisprudence, the U.S. Supreme Court will decide whether the controversial mandatory repatriation tax (MRT), created by the 2017 Tax Cuts and Jobs Act (TCJA), is unconstitutional under the 16th Amendment. The case is Charles G. Moore et al. v. United States, Case
As reported in our last news alert, the IRS is moving aggressively to investigate Malta Pension Plans. This is after naming Malta Pension Plans to the IRS’s Dirty Dozen (its annual list of abusive transactions), issuing a Competent Authority Arrangement walking back the tax benefits otherwise allowed under the U.S.-Malta
The New York State Bar Association (NYSBA) Tax Section published Report No. 1478 on June 18, 2023 to provide comments on the IRS’s recent proposal (in Notice 2023-27) to tax certain NFTs as “collectibles” under section 408 of the Internal Revenue Code. As a member of the NYSBA Tax Section
Don Fort participates in the Cambridge Forum on International Tax & Disputes in Cascais, Portugal. Description: The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of
Caroline D. Ciraolo co-chairs the Cambridge Forum on International Tax & Disputes in Cascais, Portugal. Description: The Forum Steering Committee welcomes up to 40 leading lawyers personally selected from renowned regional, national, and multinational firms around the world. With increased transparency and information sharing amongst tax authorities, the use of
Caroline D. Ciraolo leads a discussion titled “You’ve Got a Friend – Leveraging Relationships with Treaty Partners…” at the Forum on International Tax & Disputes presented by Cambridge Forums. Description: Faced with substantial tax gaps, aggressive tax avoidance, and abusive tax structures, tax authorities around the world are increasing civil
On May 3, 2023, Megan L. Brackney participates in a panel titled “Hot Button Topics with the IRS: A Conversation with Three Tax Controversy Practitioners” for STEP NY. Description: In this panel, Lawrence Lipoff leads a conversation with Megan L. Brackney, Thomas Ostrander and Miri Forster, three tax controversy experts, about
On May 25, 2023, Heather Fincher presents on a panel entitled, “What to do when Advisors Find Errors in International Tax Returns” at the Procopio International Tax Institute 2023 International Update: U.S. – Mexico Cross-Border Tax Issues. Description: Heather is moderating an engaging discussion of real-life hypos, common mistakes, and
