Proposed Regs Could Cast a Wider Net for Microcaptive Scrutiny

by Chandra Wallace The microcaptive reportable transaction regulations proposed April 10 mean a whole new set of transactions are now listed transactions — considered abusive by ...

Civil War II : The Constitutionality of California’s Travel Bans

Abstract California, along with a few other states leaning toward the liberal side of America’s political system, enacted a series of laws banning state-funded or state-sponsored ...

The Ruling on Reserve Mechanical Corp. v. Commissioner, and Impact to Captive Insurance Tax Benefits

Beckett Cantley  Geoffrey Dietrich This article provides an overview of the May 13 th , 2022, U.S. Tenth Circuit Court of Appeals decision in Reserve Mechanical Corp. v. Commissio ...

Biden Signs $1.5 Trillion Spending Bill Without Tax Offsets

Are The “Build Back Better” Taxes Lurking? By Beckett Cantley 1 & Geoffrey Dietrich 2 On March 10, 2022, the U.S. Senate voted 68-31 to pass the Fiscal Year (FY) 20 ...

CIC Services v. IRS: the Supreme Court Hands the IRS a Major Loss

AbstractThe Anti-Injunction Act (“AIA”) is an important part of administrative procedure law and a crucial piece of the United States tax system. Enacted to help expedite the t ...