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02.18.2021
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
02.17.2021
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
02.17.2021
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.
02.16.2021
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
02.05.2021
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
01.27.2021
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
12.15.2020
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?
12.09.2020
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
12.09.2020
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!)
09.19.2020
Government files final briefs in two cases
Government files final briefs in two cases
08.31.2020
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
08.27.2020
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
08.26.2020
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
08.25.2020
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
08.20.2020
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
08.08.2020
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
07.21.2020
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
07.21.2020
BIGGEST WIN YET!!!
Yesterday, Treasury issues final regulations that exclude from the GILTI regime all corporate income…
BIGGEST WIN YET!!!
07.20.2020
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
07.15.2020
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
07.15.2020
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
07.10.2020
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
07.10.2020
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!
07.08.2020
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
07.01.2020
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
06.22.2020
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
06.16.2020
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
06.15.2020
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
06.12.2020
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
06.12.2020
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!!!
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