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Grecian Magnesite Put To Bed: Tax Court Ruling Affirmed On Appeal
Recently, the Court of Appeals for the D.C. Circuit affirmed the 2017 Tax Court ruling in the matter of Grecian Magnesite Mining v. Commr., which held that a foreign corporation was not liable for U.S. tax on the gain ...
United States
11 Jul 2019
Missed Opportunities – Tax Court Shows No Mercy For Indirect Partner
At first, it may seem that the I.R.S. was harsh in determining that the taxpayer missed his chance to contest the F.P.A.A. for the two partnerships he held indirectly through another partnership.
United States
19 Jun 2019
Texas District Court On Anti-Inversion Legislation – One Down But Not Out
In October, the U.S. District Court for the Western District of Texas struck down a provision under temporary anti-inversion regulations for violating the required notice and comment period...
United States
8 Dec 2017
The Changing Face Of Service Permanent Establishments
The Johannesburg Tax Court reached a similar conclusion, albeit along a different path, in a case that addressed a matter involving a U.S. service provider.
United States
16 Nov 2017
A Case Of Nonacquiescence: I.R.S. Opposes Bartell Decision
The I.R.S. has announced that it disagrees with the ruling in Bartell v. Commr.1 in an Action on Decision ("A.O.D.") issued on August 14, 2017, expressing its "nonacquiescence" with the case.
United States
5 Oct 2017
Sale Of An Interest By A Foreign Partner – Is Rev. Rul. 91-32 Based On Law Or Administrative Wishes?
In Rev. Rul. 91-32, the I.R.S. announced its view that foreign partners in partnerships operating in the U.S. are properly taxed on their capital gains under a look-thru rule to the assets owned by...
United States
14 Jul 2017
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