Hosny Discusses an Approach to Adjust a Tax Gross-Up by the Recipient’s Tax Benefits
Islame Hosny, a Counsel in Pryor Cashman’s Tax Group, wrote an article, “The Anti-Gross-Up: Reducing the Tax Gross-Up by the Recipient’s Tax Benefits,” that appears in the September 2024 issue of Thomson Reuters’ Journal of Taxation.
In this article, Islame expands on his earlier work discussing the mechanics of tax gross-up arrangements and presents an approach for adjusting a tax gross-up to take into account the recipient’s tax benefits generated by the grossed-up payment. Islame explains that properly determining the amount of that adjustment, coined the “anti-gross-up,” could help lower the risk of over- or under-compensating the recipient as a result of the gross-up. The article develops and proposes a formula that not only grosses up a payment but also simultaneously reduces the payment by the anti-gross-up.
Read the full article by clicking the “Download a PDF of this piece” link above.
The Anti-Gross-Up: Reducing the Tax Gross-Up by the Recipient's Tax Benefits, Islame Hosny, Journal of Taxation, Volume 141, Issue 1, Copyright 2024 Thomson Reuters/Tax & Accounting
