Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On December 5, 2023, the US Supreme Court heard oral arguments in Moore v. United States, addressing the constitutionality of the section 965 transition tax, which was enacted in the Tax Cuts and Jobs Act of 2017. Section 965...more
12/27/2023
/ Apportionment ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
International Tax Issues ,
Moore v US ,
Oral Argument ,
SCOTUS ,
Sixteenth Amendment ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Liability
On December 19, 2023, the recently ratified Convention Between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal...more
At the request of concerned countries, the Organisation for Economic Co-operation and Development (OECD) Secretariat has weighed in on tax considerations that are important both to businesses and to their employees as they...more
On July 13, 2017, the Tax Court, in Grecian Magnesite, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. 3 (2017), rejected Internal Revenue Service (IRS) arguments that, in order to establish good faith reliance, the...more