Elizabeth Stevens Moderates Panel on Claims of Bona Fide Residency at NYU Tax Controversy Forum

The IRS continues its cross-border efforts to scrutinize and challenge U.S. taxpayer’s claims of Puerto Rico and U.S. Virgin Islands bona fide residency and related income-sourcing positions, as well as the investment in and use of Malta pension plans. This panel will review the taxpayer arguments with respect to these tax-advantaged transactions, the response of the IRS and DOJ, trends in audits, administrative appeals, and civil litigation, and parallel criminal investigations. The panelists will offer their views of what we can expect in the coming year and strategies for managing these disputes.