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
Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more