The final regulations are the latest (and possibly final) salvo in the IRS's attack on a controversial form of cross-border reorganization.
Interpreting the double tax treaty meaning of ‘residence’.
On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced a bill that would allow individuals to pay their federal income tax using Bitcoin.
The First-tier Tribunal clarifies the treatment of loan relationship debits after a company migrates to the UK.
With billions already invested in clean energy projects, the future of energy tax credits sales remains uncertain as we head into the election.
In ongoing litigation over the application of the economic substance doctrine, Liberty Global and the government have filed briefs to support their positions in Liberty Global’s appeal to the Tenth Circuit.