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Internal Revenue Code (IRC) Tax Court Dividends

Husch Blackwell LLP

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Blank Rome LLP

New Jersey Tax Court Rules That Individuals Are Not Subject to Tax on “Deemed Dividends” under IRC Section 965

Blank Rome LLP on

The New Jersey Tax Court has held that individual taxpayers were not required to include in their New Jersey gross income the undistributed earnings of controlled foreign corporations (“CFCs”) for purposes of the Gross Income...more

Freeman Law

Tax Court Addresses a Difference in Dates in the TCJA

Freeman Law on

In Varian Medical Systems, Inc. v. Commissioner, the Tax Court addressed a seeming oversight in the Tax Cuts and Jobs Act of 2017 (the “TCJA”) involving the effective dates for amendments to section 78 and the enactment of...more

Foley & Lardner LLP

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

Foley & Lardner LLP on

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Skadden, Arps, Slate, Meagher & Flom LLP

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

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

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