D.C. Circuit Revives Taxpayer’s GILTI Reporting Rules Challenge

The US owner of an Israeli company may proceed with his lawsuit challenging regulations put into effect by a tax on global intangible low-taxed income because a federal trial court needs to flesh out more arguments, the D.C. Circuit said Friday.

Monte Silver and his business sued the IRS for its alleged failure to consider the concerns of small businesses when making rules to enforce the GILTI tax, which effectively imposes a worldwide minimum tax on the earnings of US businesses’ foreign affiliates. He appealed after a district court dismissed his case as trying to restrain the assessment or collection ...