Blog And Media Coverage

Government files final briefs in two cases

Government files final briefs in two cases

Harvard Law School files Amicus brief

The Harvard Law School Tax Clinic (HLSTC) filed an Amicus brief in support of our motion for summary…
Harvard Law School files Amicus brief

Tax Notes covers Treasury/IRS motion to dismiss GILTI lawsuit

Two months after it was filed, the United States is asking a court to dismiss a suit challenging the…
Tax Notes covers Treasury/IRS motion to dismiss GILTI lawsuit

Law360: US Urges DC Court To Toss Suit Challenging GILTI Regs

By David HansenA D.C. federal court must dismiss a challenge to IRS regulations governing the…
Law360: US Urges DC Court To Toss Suit Challenging GILTI Regs

Treasury/IRS file motion to dismiss GILTI lawsuit

Government files motion to dismiss GILTI lawsuit. Same old tired losing arguments.To see the…
Treasury/IRS file motion to dismiss GILTI lawsuit

Silver files reply brief in summary judgement

Andrew VelardeAugust 19, 2020 A taxpayer is putting the finishing touches on his…
Silver files reply brief in summary judgement

Tax Notes Federal feature article: Silver and Altera: Modern-Day Tales of David and Goliath

Silver and Altera: Modern-Day Tales of David and GoliathThis article I wrote appears in…
Tax Notes Federal feature article: Silver and Altera: Modern-Day Tales of David and Goliath

Bloomberg: In summary judgement, Treasury seeks dismissal of Transition Tax lawsuit

A federal district court should dismiss a challenge to regulations related to a new tax for certain…
Bloomberg: In summary judgement, Treasury seeks dismissal of Transition Tax lawsuit

BIGGEST WIN YET!!!

Yesterday, Treasury issues final regulations that exclude from the GILTI regime all corporate income…
BIGGEST WIN YET!!!

MAJOR WIN!!!! Individuals' GILTI Deduction Eligibility Win Just Got Sweeter

ANDREW VELARDEContact AuthorLast year’s key victory for individuals seeking to reduce their…
MAJOR WIN!!!! Individuals' GILTI Deduction Eligibility Win Just Got Sweeter

Not GILTI. Global webinar on the 2 recent regulatory wins

As you may know, in the last week, Treasury issued two GILTI-related final regulations which greatly…
Not GILTI. Global webinar on the 2 recent regulatory wins

Expat Group Incensed Over GILTI Regs’ Small Business Brush-Off

An advocacy group representing the interests of American expatriates is calling Treasury out on its…
Expat Group Incensed Over GILTI Regs’ Small Business Brush-Off

5 Federal Tax Cases To Watch In The 2nd Half Of 2020

5 Federal Tax Cases To Watch In The 2nd Half Of 2020By Amy Lee Rosen · July…
5 Federal Tax Cases To Watch In The 2nd Half Of 2020

Final GILTI-related regulations deliver HUGE win for our advocacy!

Final GILTI-related regulations deliver HUGE win for our advocacy!Today Treasury issued…
Final GILTI-related regulations deliver HUGE win for our advocacy!

The American: Relief Success for American Overseas Small Businesses in GILTI Tax Case

The American - the leading publication for Americans overseas - covers our GILTI…
The American: Relief Success for American Overseas Small Businesses in GILTI Tax Case

Jerusalem Post: GILTI regulations are a big win for small businesses

By MONTE SILVER   JULY 23, 2020 21:38This is an important article for US…
Jerusalem Post: GILTI regulations are a big win for small businesses

Tax Notes covers our GILTI lawsuit

ANDREW VELARDEContact AuthorA taxpayer has delivered on his promised suit against the global…
Tax Notes covers our GILTI lawsuit

Motion for summary judgment filed in Transition Tax lawsuit

Five days before the deadline, and in what is the final major step of this lawsuit, today we filed a…
Motion for summary judgment filed in Transition Tax lawsuit

Republican Expat Group Takes Treasury to Task for Reg Failure

The political organization Republicans Overseas* Inc. is throwing its support behind a small…
Republican Expat Group Takes Treasury to Task for Reg Failure

Law360 on our GILTI lawsuit

By David Hansen · June 12, 2020, 8:14 PM EDTThe U.S. Treasury Department's final…
Law360 on our GILTI lawsuit

GILTI lawsuit filed!!!

In a follow up suit, we filed a GILTI lawsuit alleging that Treasury/IRS violated the RFA and PRA…
GILTI lawsuit filed!!!

Silver files final brief in support of Transition Tax summary judgement

See brief at https://drive.google.com/file/d/1qCMBdYdoPFD2IHdJcgohWyuw63LWXWBS/view?usp=sharing
Silver files final brief in support of Transition Tax summary judgement

Reg Challenge Finds Ally in Center for Taxpayer Rights

The Center for Taxpayer Rights is joining the fray in an administrative law challenge to the…
Reg Challenge Finds Ally in Center for Taxpayer Rights

Law360 covers our motion for summary judgement

To read article, see…
Law360 covers our motion for summary judgement

We caught Treasury/IRS hiding documents & file a motion to compel. Dirty tricks. This will hurt!

Not only did Treasury/IRS not comply with the RFA or PRA. Not only did they delay an entire year in…
We caught Treasury/IRS hiding documents & file a motion to compel. Dirty tricks. This will hurt!

Bloomberg: Silver files Summary judgement in Transition tax case

May 15, 2020, 2:13 PM· Case centers on whether officials followed procedures when issuing…
Bloomberg: Silver files Summary judgement in Transition tax case

Completeness of Administrative Record Challenged in Silver

The plaintiffs in a lawsuit challenging the validity of the transition tax regulations are…
Completeness of Administrative Record Challenged in Silver

Silver Moves for Summary Judgment in Transition Tax Suit

Andrew at Tax Notes provides a solid article on the motion for summary judgment.…
Silver Moves for Summary Judgment in Transition Tax Suit

The Banking industry Failed. The Insurance industry Failed. Our crowdfunded lawsuit won.

https://news.bloombergtax.com/daily-tax-report/special-treatment-for-tax-regulations-faces-latest-legal-test…
The Banking industry Failed. The Insurance industry Failed. Our crowdfunded lawsuit won.

Federalist Society hosts event on our case

hallenges to Tax RegulationsAdministrative Law Practice GroupUntil recently, the Internal Revenue…
Federalist Society hosts event on our case