November 02, 2021
A D.C. federal court won't reconsider tossing an expatriate attorney's challenge to Internal Revenue Service regulations governing a one-time tax on repatriated foreign earnings but revised its opinion to say his law practice has standing to challenge the rules.
July 02, 2021
Federal courts handed down a number of significant tax decisions in the first half of 2021, including multiple rulings concerning foreign bank account reporting failures, where judges generally went easy on inadvertent nonfilers while upholding harsh penalties for willful violations. Here, Law360 presents the top international tax cases from the first half of 2021.
July 21, 2020
A D.C. federal court should dismiss an expatriate attorney's challenge to Internal Revenue Service regulations governing the transition tax on foreign earnings because suits that interfere with tax collection are barred, the U.S. said.
July 10, 2020
In the remainder of the year, federal courts will examine several administrative law challenges to tax regulations along with questions of whether preventing some taxpaying Americans from receiving COVID-19 stimulus checks violates constitutional law and how attorney-client privilege extends to law firm client lists. Here, Law360 looks at five federal tax cases to watch in the second half of 2020.
May 18, 2020
IRS regulations governing the transition tax on foreign earnings are too onerous for small businesses and shouldn't be enforced until an analysis of their compliance burden can be completed, a taxpayer advocacy group told a D.C. federal court Monday.
May 16, 2020
The Internal Revenue Service must stop enforcing a tax on overseas profits because the agency wrongly concluded that the burden of calculating the tax would not hurt small businesses, an expatriate attorney told a federal court Friday.
January 30, 2019
The IRS violated several administrative laws when it recently issued "impenetrable" final regulations on the Tax Cuts and Jobs Act, an expatriate attorney argued in a complaint filed Wednesday to the U.S. District Court for the District of Columbia.