The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more
5/17/2024
/ Administrative Procedure ,
Appeals ,
Enforcement Authority ,
Foreign Corporations ,
Foreign Tax ,
Foreign Tax Credits ,
Internal Revenue Code (IRC) ,
Penalties ,
Reporting Requirements ,
Reversal ,
Stare Decisis ,
Statutory Authority ,
Tax Assessment ,
Tax Court
By way of background, the budget that the president submits to Congress contains estimates of federal government income and spending for the upcoming fiscal year and also recommends funding levels for the federal government....more
6/4/2021
/ Appropriations Bill ,
Biden Administration ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Internal Revenue Code (IRC) ,
IRS ,
OECD ,
Proposed Legislation ,
Tax Reform ,
U.S. Treasury
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
3/10/2021
/ Appeals ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Puerto Rico ,
Remand ,
Residency Requirements ,
Statute of Limitations ,
Tax Court ,
Tax Returns ,
Virgin Islands
A U.S. shareholder of a foreign corporation generally is not subject to U.S. federal income tax on the income of the foreign corporation until the shareholder receives an actual distribution from the corporation. However,...more