Mark Allison Quoted in CCH Regarding U.S. Virgin Islands Tax Controversy


Mark D. Allison is quoted by CCH concerning the Third Circuit's reversal of a district court decision finding that a taxpayer's desire to change residency in order to take advantage of lawful tax incentives does not undermine his or her claim of bona fide residency. For the complete article, please visit CCH's website.

Excerpt taken from the article.

"The decision affirms the important principle that taxpayers can freely choose their residence, even if such a decision is based on the motivation of reducing or eliminating their taxes," Mark Allison, member, Caplin & Drysdale, Chartered, New York, told CCH. "Many jurisdictions, including state and local governments, provide incentives through lower taxes or abatements to attract taxpayers – both individuals and businesses – as a means of growing their economy and creating jobs. Assuming that the residence is bona fide, the IRS should not be in the position to offer taxpayers the carrot of Congressionally-mandated incentives only to use the stick to deprive those benefits because the IRS does not like the taxpayers' reasons for claiming such benefits," Allison said.


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