Silver & Co.

Hi All: Our cases raise many serious precedent-setting issues, such as procedural standing, AIA, RFA, PRA. And this is before we even get...

The National Taxpayer Advocate - an independent organization within the IRS - dedicated 2 pages of its report to congress to our cases! ...

Success Stories of U.S. & International Experts Day: Tuesday July 13, 2021 Time: 10am London, 11 am Paris/Germany, 12 noon Israel,...

Some things are sweet. Some things painful. In our advocacy we have tasted, and will continue to taste, both. This one is very sweet,...

Appeal in Transition tax case filed, in addition to our motion to ask the first court to reconsider. IRS/Treasury, if you read this we...

As you may recall, the Supreme Court took up a case involving the Anti-Injunction Act - one of the key defences that the Treasury has in...

By David Hansen · April 23, 2021, 7:10 PM EDT A federal court should reconsider its ruling that an expatriate attorney lacked standing to...

https://drive.google.com/file/d/1iUuhe52pj0g78uFvS5mUWVyGZVwhLsfV/view?usp=sharing

Hi All: We took a hit and were knocked down. But we got up again and came back fighting in both cases. We filed a few motions a few...

Here is the judgment against us in the Transition tax case. https://drive.google.com/file/d/13ht9aMBBVO6z0yUYJ2oUQtem9hZ6gXCC/view?usp=sh...

A court is homing in on what is a sufficient compliance burden under transition tax regs as the government seeks to beat back a suit...

By Aysha Bagchi (Bloomberg Law) -- Oral arguments in a lawsuit challenging the validity of rules implementing part of the 2017 tax...

A federal court won't rule on whether an Israeli law firm can challenge IRS regulations governing the tax on global intangible low-taxed...

Court Stays Silver’s GILTI Reg Challenge Suit February 17 By Andrew Velandre A district court has stayed a challenge to the global...

The judge in the GILTI action has put the case on hold until the judge in the Transition tax case issues final judgment. (See order...

Law360 (February 12, 2021, 6:42 PM EST) -- Monte Silver This article discusses the opportunities that small and medium-sized businesses...

Congress releases draft COVID bill. Here are two of the main provisions at may impact expats: Giving working families an additional...

In December 2017, the Tax Cuts and Jobs Act became law. The TCJA’s international provisions sought to accomplish one main and important...

Trusts - core issues that Americans abroad should contemplate when assessing using a trust Webinar Wednesday February 10, 2021 Given the...

By Amy Lee Rosen· January 26, 2021, 7:27 PM EST The government likely will spend a lot of time in the future monitoring challenges and...