Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.
The Treasury Department is trying to capture more international income by arguing for a broadly applicable economic substance doctrine, taking an expansive view of controlled foreign corporation status, and taxing income allocations a taxpayer says don’t comply with foreign laws.
Here are three cases tax practitioners should watch next year:
Liberty Global Inc. v. United States
The IRS could have more discretion to crack down on tax-advantaged restructuring transactions if the US ...
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