GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more
By Jonathan H. Freiberger The Courts of New York will not aid in the enforcement of a contract when the subject matter is illegal. Cases standing for this seemingly unremarkable proposition are varied. For example, in...more
Dr. Rogelio Ramírez de la O, Secretario de Hacienda y Crédito Público de México, el 8 de septiembre de 2023, presentó ante la Cámara de Diputados el Paquete Económico para el 2024 (PE 2024), mismo que no contempla aumentos,...more
Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more
Key Takeaways - ..Taxpayers could be criminally and civilly liable under state False Claims Act statutes for underreporting income linked to virtual currency. ..While the federal False Claims Act explicitly excludes tax...more
In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more
On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more