Judges Grill IRS, Taxpayer in Challenge to GILTI Reporting Rules

A US appeals court judge on Thursday questioned an Israeli company’s standing to challenge international tax regulations put into effect by the 2017 Republican tax law, but was also skeptical of the IRS’s reasoning as to why the court should support tossing the lawsuit.

Monte Silver appealed after his case was dismissed under the Anti-Injunction Act, which bars suits for the purpose of restraining the assessment or collection of any tax.

The district court sided with the IRS after concluding that the purpose of Silver’s suit was to defer enforcement of the law’s global intangible low-taxed income provision, which targets ...