IRS, Treasury Sued Over Repatriation Tax Rules

A U.S. citizen based in Israel has sued the IRS and Treasury Department, challenging the validity of regulations for the transition tax—on accumulated assets outside the U.S.—as they apply to controlled foreign corporations.

• The Jan. 30 complaint says “impenetrable” rules for the transition tax, or repatriation tax, violate the Administrative Procedure Act, the Regulatory Flexibility Act, and the Paperwork Reduction Act—aimed, at least in part, at reducing the compliance burden on small businesses
• Monte Silver, who owns an accounting and law firm in Israel, seeks a rule change that provides relief for CFCs, in which case the tax wouldn’t be ...