As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
1/29/2025
/ Corporate Counsel ,
Double Taxation ,
Foreign Corporations ,
Foreign Nationals ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
OECD ,
Pillar 2 ,
Tax Liability ,
Tax Rates ,
Tax Reform ,
Tax Treaty ,
Trump Administration ,
U.S. Treasury
A Treasury regulation provides that a researcher performing technological research for its customer is not entitled to federal income tax credits for the cost of the research if the researcher does not retain substantial...more
Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable.
The...more
Key Takeaways -
..The pending case, Silver v. Internal Revenue Service, will provide insight, when decided, of the view of the Court of Appeals for the District of Columbia Circuit on the scope of judicial review of...more
6/27/2022
/ Administrative Appeals ,
Appeals ,
Article III ,
Income Taxes ,
Judicial Review ,
NPRM ,
Regulatory Flexibility Act ,
Reporting Requirements ,
Small Business ,
Standing ,
U.S. Treasury