Monte Silver, Tax lawyer5 days ago1 minTransition tax is constitutional, rules US Federal courtThe issue of whether the Transition tax is constitutional, given the retroactive nature of the tax, has been of interest to many. The fed...
Monte Silver, Tax lawyerNov 103 minOn ecommerce and sales tax. Updates and webinarImagine you sell things (goods or services) online to US-based customers. Given the coronavirus, people are buying more on-line, and you...
Monte Silver, Tax lawyerSep 61 minSilver files final brief in support of Transition Tax summary judgementSee brief at https://drive.google.com/file/d/1_HsgmhFYYtDTbFPTodWgbDuXVi03K-FX/view?usp=sharing
Monte Silver, Tax lawyerAug 271 minLaw360: US Urges DC Court To Toss Suit Challenging GILTI RegsBy David Hansen A D.C. federal court must dismiss a challenge to IRS regulations governing the transition tax on foreign earnings because...
Monte Silver, Tax lawyerAug 261 minTax Notes covers Treasury/IRS motion to dismiss GILTI lawsuitTwo months after it was filed, the United States is asking a court to dismiss a suit challenging the global intangible low-taxed income r...
Monte Silver, Tax lawyerAug 251 minGovernment files motion to dismiss GILTI lawsuit. Same old arguments. Government files motion to dismiss GILTI lawsuit. Same old tired losing arguments. To see the motion, see https://drive.google.com/file/...
Monte Silver, Tax lawyerAug 201 minTax Notes: Silver files final brief in support of summary judgement in Transition tax caseAndrew Velarde August 19, 2020 A taxpayer is putting the finishing touches on his summary judgment argument challenging the transition ta...
Monte Silver, Tax lawyerAug 81 minExpat Group Incensed Over GILTI Regs’ Small Business Brush-OffAn advocacy group representing the interests of American expatriates is calling Treasury out on its global intangible low-taxed income hi...
Monte Silver, Tax lawyerAug 81 minSilver and Altera: Modern-Day Tales of David and GoliathThis article I wrote appears in Tax Notes Federal, an online and offline publication. It is one of best articles I have ever published. ...
Monte Silver, Tax lawyerJul 231 minGILTI TAX WEBINAR - Thursday July 30As you may know, in the last week, Treasury issued two GILTI-related final regulations which greatly benefit small business owners. It...
Monte Silver, Tax lawyerJul 221 minAmerican Expat Financial News: Partial' GILTI tax victory seen in latest Treasury regsThe U.S. Treasury Department on Monday issued what it said was a "final regulation" addressing how income earned by foreign corporations ...
Monte Silver, Tax lawyerJul 221 minWIN!!!!!!!!!!! Treasury's final regs yesterday provides us GILTI exemption Yesterday, Treasury issues final regulations that exclude from the GILTI regime all corporate income which is taxed at least 18.9% in the...
Monte Silver, Tax lawyerJul 202 minBloomberg: In summary judgement, Treasury seeks dismissal of Transition Tax lawsuit A federal district court should dismiss a challenge to regulations related to a new tax for certain U.S. shareholders of foreign companie...
Monte Silver, Tax lawyerJul 153 min5 Federal Tax Cases To Watch In The 2nd Half Of 20205 Federal Tax Cases To Watch In The 2nd Half Of 2020 By Amy Lee Rosen · July 10, 2020, 8:21 PM EDT In the remainder of the year, federal...
Monte Silver, Tax lawyerJul 131 minThe American: Relief Success for American Overseas Small Businesses in GILTI Tax CaseThe American - the leading publication for Americans overseas - covers our GILTI win. https://www.theamerican.co.uk/pr/ne-GILTI-Tax-Succe...
Monte Silver, Tax lawyerJul 113 minTax Notes: Treasury final GILTI regulation delivers big regulatory win for smaller businesses Individuals' GILTI Deduction Eligibility Win Just Got Sweeter Posted on Jul. 13, 2020 By Andrew Velarde Last year’s key victory for indiv...
Monte Silver, Tax lawyerJul 91 minFinal GILTI-related regulations deliver HUGE win for our advocacy!Today Treasury issued final regs related to GILTI. These regs relate directly to American expats and US based Americans that operate bus...
Monte Silver, Tax lawyerJun 191 minFocused on TCJA compliance, IRS chase the rich international taxpayerswww.law360.com/tax-authority/federal/articles/1283418/irs-to-review-hundreds-of-high-wealth-returns-official-says-?nl_pk=896f75fb-2a9d-4a...
Monte Silver, Tax lawyerJun 153 minTax360: Harvard submits Amicus in Transition case By Dylan Moroses · May 18, 2020, 6:57 PM EDT IRS regulations governing the transition tax on foreign earnings are too onerous for small b...
Monte Silver, Tax lawyerJun 153 minLaw360 covers GILTI lawsuitBy David Hansen · June 12, 2020, 8:14 PM EDT The U.S. Treasury Department's final regulations implementing the tax on global intangible l...
