The Methods (and Madness) of Transfer Pricing for Tangible and Intangible Property
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Oct 28, 2022 Cross-Border Tax Insights, International Tax
Tax Court in Brief | Richard J. O’Neill Trust v. Comm’r | Application for Tentative Refund, Claim of Right, Mitigation, and Equitable Recoupment
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Oct 28, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Tax Court in Brief | Manzolillo v. Comm’r | Preclusion for Deficiency Determination, IRS Form 8962 and Premium Tax Credit
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Oct 28, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Whirlpool Petition for Cert
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Oct 27, 2022 Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Subpart F
Plan Loan Offsets | What happens to a loan against a qualified retirement plan when the plan or employment is terminated?
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Oct 24, 2022 Loans, Tax Concepts
Withdrawal of 2006 Proposed PTEP Regulations
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Oct 21, 2022 Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, Subpart F
Tax Court in Brief | Yaguda v. Comm’r | Taxation of Unearned Income of Child; Income from S Corp; Accuracy-Related Penalty
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Oct 21, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Tax Court in Brief | Champions Retreat Golf Founders, LLC v. Comm’r | Conservation Easement Valuation; Highest and Best Use; Battle of Experts
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Oct 21, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Gain Recognition Agreements and Outbound Stock Transfers
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Oct 19, 2022 Cross-Border Tax Insights, Form 926, Gain Recognition Agreement, GRA, International Tax, IRS Disclosure, IRS Regulations, Outbound Stock Transfer, Outbound Transfer, Section 367, Section 6038B, Tax Compliance, Tax Planning
Tax Court in Brief | Clark Raymond & Co., PLLC v. Comm’r | Partnership Intangible Assets, Economic Effect and Treas. Reg. § 1.704-1
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Oct 14, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Tax Court in Brief | Scheider v. Comm’r | Deficiency for Unreported Income; Burdens of Proof
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Oct 14, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Tax Court in Brief | Cochran v. Comm’r | Tax Court Proceeding and Automatic Stay in Bankruptcy
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Oct 14, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Service of Process on a Decentralized Autonomous Organization
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Oct 12, 2022 Bitcoin, Blockchain, Cryptocurrency, Litigation
Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional
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Oct 07, 2022 Tax Court, The-Tax-Court-in-Brief Insights
Tax Court in Brief | Sander v. Comm’r | Standing to Contest Deficiency of Another
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Oct 07, 2022 Tax Court, The-Tax-Court-in-Brief Insights