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CASE REVIEW – TAXPAYER WINS FOREIGN TAX CREDIT NIIT CASE

Dec 26, 2024

In this week’s blog, we review a case representing a major win for taxpayers, in which the U.S. Court of Federal Claims concluded that a treaty allows foreign tax credits to offset the net investment income tax.

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SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Aug 26, 2024

In this week’s blog, we discuss a recent Supreme Court decision upholding the constitutionality of the Section 965 transition tax, as well as the impact the decision could have on current filers, particularly those catching up using the Streamlined Procedures.

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Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

May 20, 2024

In this week’s blog, we review the D.C. Circuits Court’s reversal of the Farhy decision, a surprising case from last year holding that the IRS lacks the statutory authority to assess certain international return penalties.

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CASE REVIEW – TAXPAYER WINS FOREIGN TAX CREDIT NIIT CASE

SUPREME COURT RULES ON CONSTITUTIONALITY OF TRANSITION TAX

Circuit Court Reverses Taxpayer-Friendly Decision on Form 5471 Penalties

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