Tax Law News and Insights

On June 20, 2024, the U.S. Supreme Court ruled 7-2 that the so called mandatory repatriation tax under Internal Revenue Code Section 965 ("MRT") is constitutional. Justice Kavanaugh wrote the majority opinion. Justice Thomas (joined by Justice Gorsuch) dissented. Justice Barrett (joined by Justice Alito) and Justice Jackson delivered separate concurring opinions....

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Highlights The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the taxpayer, the Tax Court rejected the IRS argument that either the common law "conduit" doctrine...

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On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would mean that taxpayers and material advisors who participated in these CRATs would have to comply with lengthy disclosure...

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