I recently had the opportunity to review all 50 state constitutions and confirmed an important fact for the current capital gains income tax litigation. Although most state constitutions mention how ...

With the 9th Circuit Court of Appeal’s recent decision in Amazon.com Inc. et al v Commissioner of Internal Revenue, upholding a U.S. Tax Court ruling rejecting a broader definition of intangible ...

On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section ...