David Shapiro, Chair of Tax and Employee Benefits Practice at Saul Ewing LLP, will moderate a session at the ABA Section of Taxation Virtual Fall Meeting on September 27, 2024. The topic will be Foreign and U.S. Taxation - Individuals & Passthroughs; Mirror, Mirror – A Look into the Tax System Relating to U.S. Territories.
There are five populated U.S. Territories: the Commonwealth of Puerto Rico, the Virgin Islands of the United States, the Commonwealth of the Northern Mariana Islands, American Samoa, and Guam. This panel will discuss the history and operation of (i) certain Internal Revenue Code provisions relating those territories and (ii) those territories’ internal systems of taxation, including so-called “mirror codes.” Topics to be covered include distinctions between mirror and non-mirror territorial tax rules, territory sourcing and residency issues, and how territorial rules interact with other Code provisions of particular relevance to individuals and closely held businesses.
Moderator: David Shapiro, Saul Ewing LLP
Panelists: Lawrence Barusch, Parsons Behle & Latimer; Bibiana Cruz, Holland & Knight LLP; Marjorie (Jorie) Rawls Roberts, Marjorie Rawls Roberts, PC; Cleve Lisecki, IRS Associate Chief Counsel (International) Branch 7
Learning Objectives: After attending the session, the participant will be able to:
• Overview of history and operation of mirror codes
• Distinctions between mirror code and non-mirror code territorial rules
• Territory sourcing and residency issues
• Interaction of mirror codes with GILTI and other Code tax provisions
