Blog And Media Coverage

Court Stays GILTI Challenge Pending Outcome Of Similar Case

Court Stays GILTI Challenge Pending Outcome Of Similar CaseBy David Hansen  February 17,…
Court Stays GILTI Challenge Pending Outcome Of Similar Case

Tax Notes on motion to stay GILTI action

Court Stays Silver’s GILTI Reg Challenge Suit February 17By Andrew Velandre A…
Tax Notes on motion to stay GILTI action

How small and medium-sized businesses can obtain tax and tax compliance-related relief during President Joe Biden's term.

Law360 (February 12, 2021, 6:42 PM EST) -- Monte Silver This article discusses the…
How small and medium-sized businesses can obtain tax and tax compliance-related relief during President Joe Biden's term.

Court in GILTI lawsuit puts case on hold until judgment in Transition tax case given

The judge in the GILTI action has put the case on hold until the judge in the Transition tax…
Court in GILTI lawsuit puts case on hold until judgment in Transition tax case given

Biden on Tax: Legislation or Treasury Regs

February 5By Monte SilverIn December 2017, the Tax Cuts and Jobs Act became law. The…
Biden on Tax: Legislation or Treasury Regs

Chief IRS Counsel: Silver cases in focus

The government likely will spend a lot of time monitoring challenges and questions over regulations…
Chief IRS Counsel: Silver cases in focus

Will the Supreme Court allow Treasury to keep getting away with murder?

Will the Supreme Court allow Treasury to keep getting away with murder? For tax geeks with an…
Will the Supreme Court allow Treasury to keep getting away with murder?

Transition tax is constitutional, rules US Federal court

The issue of whether the Transition tax is constitutional, given the retroactive nature of the tax,…
Transition tax is constitutional, rules US Federal court

U.S. Supreme Court likely to prevent pre-emptive challenges to Treasury regs (but not our lawsuit!)

US Supreme Court held oral arguments in a case of CIC vs IRS, dealing with the ability of taxpayers…
U.S. Supreme Court likely to prevent pre-emptive challenges to Treasury regs (but not our lawsuit!)

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!!!