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DC Circuit Reverses Tax Court and Holds Section 883 Regulations Invalid under Chevron Test

USA - August 2 2018 On March 28, 2017, the US Tax Court (Tax Court) issued its opinion in Good Fortune Shipping SA v. Commissioner, 148 T.C. No. 10, upholding the...

Andrew R. Roberson.

E-Filing: Comments Provided to IRS Regarding Transmission Failures

USA - December 26 2017 As taxpayers are (or should be) aware, federal income tax returns must be timely filed to avoid potential penalties under Internal Revenue Code...

Andrew R. Roberson.

Governments are Pulling Back the Crypto-Currency Curtain

USA - December 13 2017 Coinbase Inc., a virtual currency exchange platform, was recently ordered by the United States District Court for the Northern District of California...

Laura L. Gavioli.

Tax Court Says IRS’s “Drift-Net” Argument to Expand Privilege Waiver Must Be Anchored in Principles

USA - November 3 2017 In Estate of Levine v. Commissioner, the US Tax Court (Tax Court) rejected an Internal Revenue Service (IRS) attempt to expand upon the privilege...

Kevin Spencer, Andrew R. Roberson.

Manafort Indictment Is a Good Reminder of FBAR Disclosure Requirements

USA - November 2 2017 On October 30, 2017, Paul Manafort Jr. was indicted for concealing his interests in several foreign bank accounts, as well as tax evasion and a host...

Kevin Spencer, Laura L. Gavioli, Andrew R. Roberson.