The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more
1/27/2020
/ Administrative Procedure Act ,
Anti-Injunction Act ,
Audits ,
Conflicts of Laws ,
Constitutional Challenges ,
Dividends ,
Expedited Actions Process ,
Foreign Corporations ,
IRS ,
Litigation Strategies ,
Shareholders ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Tax Returns
For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more
2/24/2017
/ Appeals ,
Business Taxes ,
Dividends ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Reversal ,
Roth IRA ,
Tax Benefits ,
Tax Court ,
Tax Planning ,
Tax-Free Transfers