Rethinking Taxing Excess Profits
This article discusses the application of excess profit taxes (EPTs, also referred to as windfall taxes) that have gained renewed interest and popularity over the past several years.
The Tax Lawyer | Winter 2024
Volume 77, Issue 2
Articles
Administrative Law Meets Section 501(c)(3) Charitable Purpose
In the past several years taxpayers have won a number of challenges to tax guidance based on violations of administrative law. Federal courts are blithely invalidating IRS and Treasury guidance, rang…
Not Taxing Puerto Rico? Whitewashing Impoverishment in United States v. Vaello-Madero
Puerto Rico is a lush archipelago located between the Caribbean Sea and the North Atlantic Ocean. More than three million U.S. citizens with diverse racial and ethnic histories and cultures live on t…
Blocked Income & 3M Company & Subsidiaries v. Commissioner—Round One—The Chevron Step One Argument
More than six years after the case was tried, the Tax Court issued its voluminous, reviewed decision in 3M Company & Subsidiaries v. Commissioner, in which it concluded, by a razor-thin 9-8 margin, t…