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Assessing Employer FICA Tax on the Estimated Aggregate Unreported Tips of Employees: Quietwater Entertainment, Inc. v. United States

In Quietwater Entertainment, Inc. v. United States, the U.S. District Court for the Northern District of Florida held that the Service is not authorized to assess an employer’s share of FICA taxes based on an estimate of employees’ aggregate unreported tips. The court distinguished a recent Eleventh Circuit decision, Morrison Restaurants, Inc. v. United States...

Act of State Doctrine Allows Foreign Taxes on “Net Loan” Interest Paid by a Foreign Central Bank to be Credited as a Foreign Tax Credit: Riggs National Corp. v. Commissioner

In Riggs National Corp. v. Commissioner, the U.S. Court of Appeals for the D.C. Circuit reversed the Tax Court and held that a U.S. bank which received interest payments pursuant to a net loan with the Brazilian Central Bank is entitled to foreign tax credits under section 901 for Brazilian taxes paid on its behalf by the Brazilian Central Bank. ...