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IRS Priority List Indicates Increase in International Employee Benefits Compliance Efforts (PDF)
Groom Law Group 
[Guidance Overview] Apr. 27, 2010
4 pages. Excerpt: First are issues surrounding Puerto Rico plans and 'dual status' plans. In addition to the US tax treatment of distributions (see, e.g., Rev. Proc. 2004-37) and deductions for contributions, the IRS has been working with the Hacienda in Puerto Rico to train plan auditors .... Another area appears to be the valuation of foreign plan investments and disclosures.
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