Federal Regulatory Advocacy
Financial Times world first: Small/medium businesses hit by Transition tax
Americans worldwide hammered by the Transition Tax
Thousands of American business owners living in Israel hit by Transition Tax
International Tax Review: The Problems with GILTI
US Treasury grants businesses extension to file Transition Tax tax returns
WIN!!!! American businesses worldwide receive on year reprieve from Transition Tax
Recent Government Accountability Office (GAO) report shows that Treasury always ignores RFA
Why small businesses get stuck with GILTI
Canadian Broadcast Corp: Americans living in Canada saved by the bell
WIN!! SENATE FINANCE COMM. DELIVERS DRAFT BILL EXEMPTING SMALL/MEDIUM BUSINESSES FROM TRANSITION TAX!!
My formal comment filed during the 60 day comment period of the proposed Transition tax regulations
Israeli Treasury Dept. lobbies US Treasury to seek solution for GILTI.
Treasury grants businesses second relief in 3 months!!
Bloomberg: Small businesses face harsh reality with Transition Tax
Comparing the Treasury RFA certification and what the Small Business Administration requires
Democrats Abroad, part of the Democratic party, joins the battle against the Transition tax & GILTI
Bloomberg covers Transition Tax lawsuit
Law360 covers the Transition Tax lawsuit
Seeking complete relief from the Transition Tax, businesses crowdfund to file suit against Treasury
U.S. Tax Seminar in Paris: The impact of the 15.5% Repatriation and GILTI taxes on U.S. expats
Global webinar: The Transition Tax October 15, 2018 deadline and what to do
Tax Notes covers Transition tax lawsuit
#1 Expat newspaper based in England covers Transition Tax lawsuit
Law360: Treasury announces intention to address GILTI issues for small/medium businesses
WIN!!!! Treasury provides small businesses relief in proposed GILTI regs
Bloomberg followup article to Transition Tax lawsuit
#1 publication for Americans abroad on the GILTI fix
MONSTER GILTI WIN!!!
Treasury/IRS file motion to dismiss our Transition Tax lawsuit
We file our opposition to the motion to dismiss
Treasury Moves to Dismiss Transition Tax Regs Suit Over Standing
#1 leading expat journal on the motion to dismiss
Tax Notes: Plaintiffs fire back in opposition to motion to dismiss
Calculating Transition Tax Doesn’t Give Suit Standing, DOJ Claims In Reply Brief
Law 360 discusses the technical hurdles we face in the motion to dismiss
Law360 discusses the case and its significance
WE WIN!!!! Judge's one-sided ruling crushes Treasury/IRS
#1 leading blog on procedural aspects of tax litigation explains the significance of the ruling.
Tax Notes: In depth article analyzes the significance of our surpising win
Tax Notes follow up article on the ruling
Tax Notes Feature Article: Rethinking Challenges to Treasury Regulations
Treasury files answer, Doubles Down on Spurned Arguments in Silver, Offers New Ones
Completeness of Administrative Record Challenged in Silver
Silver Moves for Summary Judgment in Transition Tax Suit
Harvard Law School files Amicus brief
Reg Challenge Finds Ally in Center for Taxpayer Rights
Republican Expat Group Takes Treasury to Task for Reg Failure
Tax Notes covers our GILTI lawsuit
MAJOR WIN!!!! Individuals' GILTI Deduction Eligibility Win Just Got Sweeter
GILTI lawsuit filed!!!
Law360 on our GILTI lawsuit
Motion for summary judgment filed in Transition Tax lawsuit
Law360 covers our motion for summary judgement
We caught Treasury/IRS hiding documents & file a motion to compel. Dirty tricks. This will hurt!
The Banking industry Failed. The Insurance industry Failed. Our crowdfunded lawsuit won.
Federalist Society hosts event on our case
Treasury/IRS produce the Administrative Record.
Monte Silver feature article in Tax Notes: So you want to challenge a Treasury regulation issued under the TCJA?
Treasury/IRS file answer to lawsuit
Our case cited in Supreme Court brief!!!
American Bar Association event on our case
5 Federal Tax Cases To Watch In The 2nd Half Of 2020
The American: Relief Success for American Overseas Small Businesses in GILTI Tax Case
Final GILTI-related regulations deliver HUGE win for our advocacy!
Law360 covers Government final reply brief
Tax360 reports on motion to dismiss: Anti-Injunction Act does not bar small business lawsuit
Global Webinar: The impact of the Repatriation and GILTI taxes on American business owners living abroad
Global Webinar: what is GILTI and what to do about it.
Handelsblatt, #1 German business publication: Americans in Germany hit by Repatriation/GILTI tax.
U.S. Tax Seminar in Munich: The impact of the 15.5% Repatriation & GILTI taxes on expats in Germany
U.S. Tax Seminar in London: The impact of the 15.5% Repatriation & GILTI taxes on expats in England
Expat Americans given one-year reprieve on US repatriation tax
BIGGEST WIN YET!!!
Not GILTI. Global webinar on the 2 recent regulatory wins
Bloomberg: In summary judgement, Treasury seeks dismissal of Transition Tax lawsuit
Bloomberg: Silver files Summary judgement in Transition tax case
Jerusalem Post: GILTI regulations are a big win for small businesses
Monte Silver joins AARO board & heads tax committee
Expat Group Incensed Over GILTI Regs’ Small Business Brush-Off
Tax Notes Federal feature article: Silver and Altera: Modern-Day Tales of David and Goliath
Silver files reply brief in summary judgement
Treasury/IRS file motion to dismiss GILTI lawsuit
Silver files final brief in support of Transition Tax summary judgement
Law360: US Urges DC Court To Toss Suit Challenging GILTI Regs
Tax Notes covers Treasury/IRS motion to dismiss GILTI lawsuit
Government files final briefs in two cases
Transition tax is constitutional, rules US Federal court
Silver covers Supreme Court case of CIC vs. IRS
U.S. Supreme Court likely to prevent pre-emptive challenges to Treasury regs (but not our lawsuit!)
Will the Supreme Court allow Treasury to keep getting away with murder?
Chief IRS Counsel: Silver cases in focus
Biden on Tax: Legislation or Treasury Regs
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
Tax Notes on motion to stay GILTI action
Court Stays GILTI Challenge Pending Outcome Of Similar Case
Mission and Business Principles