The Ruling on Reserve Mechanical Corp. v. Commissioner, and Impact to Captive Insurance Tax Benefits

31-Oct-2022

Beckett Cantley  Geoffrey Dietrich This article provides an overview of the May 13 th , 2022, U.S. Tenth Circuit Court of Appeals decision in Reserve Mechanical Corp. v. Commissio ...

Biden Signs $1.5 Trillion Spending Bill Without Tax Offsets

22-Mar-2022

Are The “Build Back Better” Taxes Lurking? By Beckett Cantley 1 & Geoffrey Dietrich 2 On March 10, 2022, the U.S. Senate voted 68-31 to pass the Fiscal Year (FY) 20 ...

CIC Services v. IRS: the Supreme Court Hands the IRS a Major Loss

02-Mar-2022

AbstractThe Anti-Injunction Act (“AIA”) is an important part of administrative procedure law and a crucial piece of the United States tax system. Enacted to help expedite the t ...

Apple v. European Commission: Losing the War on Corporate International Transfer Pricing

09-Feb-2022

Cantley Dietrich

Abstract: For the last several years, Apple has been defending tax strategies utilized in Ireland before the European Union (EU) General Court. The European Commission, using ...