Transition Tax Rules Challengers Can’t Sue, Court Says (2)

March 29, 2021, 3:35 PM; Updated: March 29, 2021, 10:57 PM

The Treasury Department won in its defense against a lawsuit claiming it failed to comply with procedural requirements when issuing major international tax rules because the plaintiffs weren’t eligible to bring the challenge, a federal court ruled.

The Sunday ruling win for Treasury came as it defended itself against allegations that it improperly issued regulations implementing tax code Section 965, a provision created through the 2017 tax law. The Section 965 transition tax, also called the mandatory repatriation tax, applies to otherwise untaxed foreign earnings for U.S. shareholders of certain foreign corporations, treating the earnings as if they were ...

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