Moore v. United States: the U.S. Supreme Court’s Impending Revisiting of the Definition of “Income”
Abstract The passing of the Tax Cuts and Jobs Act (“TCJA”) in December 2017 made significant changes that affect both domestic and international businesses income taxes. One of ...
The Resurrection of Micro-Captive Insurance
Download Word document The aggressive micro-captive insurance company industry is at severe risk of decimation. The Internal Revenue Service (IRS) initially issued Notice 2016-66 t ...
The U.S.-Malta Treaty Retirement Account: The IRS’ Latest Listed Transaction
Abstract: IRS targets Malta Retirement Scheme The IRS’s duty to ensure the public’s compliance with tax law largely involves defining what taxpayers must report on their tax re ...
Coca-Cola v. Commissioner: A Major IRS Win
A Major IRS Win in the International Transfer Pricing Wars Beckett Cantley[1] Geoffrey Dietrich[2] Abstract In Coca-Cola v. Commissioner , the IRS won a major transfer pricing ba ...
Severity Under Scrutiny: The U.S. Supreme Court Battle Over the FBAR Penalty
Abstract In recent years, Congress strengthened federal regulation of foreign bank accounts held by United States citizens. In 1970, Congress passed the Bank Secrecy Act (BSA), req ...