SILVER et al v. INTERNAL REVENUE SERVICE et al

  1. July 15, 2024

    Israeli Firm Seeks To Amend Suit Against GILTI Regs

    The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.

  2. November 09, 2022

    Jurisdiction Issue Sinks Israeli Firm's Challenge To GILTI Regs

    A D.C. federal court dismissed an Israeli law firm's challenge to the global intangible low-taxed income regulations, saying it lacked jurisdiction to defer enforcement of rules that impose tax obligations.

  3. August 25, 2020

    US Urges DC Court To Toss Suit Challenging GILTI Regs

    A D.C. federal court must dismiss a challenge to Internal Revenue Service regulations governing the transition tax on foreign earnings because the plaintiff, an expatriate attorney, lacks the physical presence needed to sue in the U.S., the government said.

  4. July 10, 2020

    5 Federal Tax Cases To Watch In The 2nd Half Of 2020

    In the remainder of the year, federal courts will examine several administrative law challenges to tax regulations along with questions of whether preventing some taxpaying Americans from receiving COVID-19 stimulus checks violates constitutional law and how attorney-client privilege extends to law firm client lists. Here, Law360 looks at five federal tax cases to watch in the second half of 2020.

  5. June 12, 2020

    Expatriate Attorney Says Treasury Must Suspend GILTI Regs

    The U.S. Treasury Department's final regulations implementing the tax on global intangible low-taxed income, a provision of the 2017 federal tax overhaul, violate administrative law and must be suspended, an expatriate attorney told a D.C. federal court Friday.