Ten Common GST Planning Mistakes
The federal generation-skipping transfer (GST) tax is arguably one of the most complex and nuanced transfer tax regimes in existence. ...
The Tax Lawyer | Winter 2021
Volume 74, Issue 2
Articles
The Taxpayer Bill of Rights and the Right to Be Informed: The Positive or Negative Way You Look at It
In 2015, Congress enacted a Taxpayer Bill of Rights. To date, it has had little impact in litigation; however, its rights could be given power through interpretation. ...
Section 267A and the Taxation of Hybrid Mismatches Under the Code
Hybrid mismatches arise because of differences in the tax rules of different countries. Such mismatched have allowed multinationals to minimize their tax liabilities. ...
Corporate Tax Integration and the TCJA: How Near the Mark?
Congress, through the Tax Cuts and Jobs Act of 2017, made a number of changes to the income tax rates applicable to individuals and profits of businesses conducted in corporate and noncorporate form.
Taxing the American Emigrant
American emigrants face many consequences from the extraterritorial application of U.S. taxation and banking policies. ...