The Recent Shift Towards Territorial Taxation of U.S. Corporations
Prior to passage of the Tax Cuts and Jobs Act (TCJA), the U.S. was the only G-7 country that taxed its corporations with headquarters in the U.S. using a worldwide tax system. Marshall J. Heap, EA
The Tax Cuts and Jobs Act Moves the U.S. Closer to a Territorial Tax System
The Tax Cuts and Jobs Act (TCJA) fundamentally changes the taxation of outbound activities of U.S. corporations and foreign corporations doing business in the U.S. and moves the U.S. international tax regime closer to a territorial system on par with other developed countrie... Sean Clancy, JD; Frank Emmons, JD; Shahzad Malik, JD
Overview of Practice Before the U.S. Tax Court
This article will focus on income tax deficiency and collection due process (CDP) jurisdiction, but the Tax Court also has jurisdiction over IRS’s denial or refusal to act on abatement of interest under IRC §6404 and innocent spouse cases under §6015; cases related to employment status; and denial of whistleblower claims, among others. The Tax Court was established to handle tax deficiency cases that require a timely filed notice of defic... Sherrill Trovato, EA, USTCP
Is the United States Tax Court a Court of Equity?
Grisel A. Smyth, Petitioner v. Commissioner of Internal Revenue, Respondent T.C. Memo. 2017-29 Filed February 7, 2017 Under the United States Constitution, the U.S. Tax Court is an Article I court. This means that the powers of the Tax Court are more restricted than those of courts that are granted pow... Steven R. Diamond, CPA
Classification of Foreign Business Entities under U.S. Tax Law
An elementary question in business international taxation involves ascertaining the classification of foreign entities for U.S. tax purposes. This question emerges whenever a foreign business pursues U.S. economic activity or when a U.S. person establishes a business outside the U.S. While foreign entities enjoy definite classification under the laws of their respective countries of organization, their classification under U.S. tax law may be... Anthony (Tony) Malik, EA, MPAcc