• Monte Silver, Tax lawyer

WE COME BACK SWINGING

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 days ago. I want to update you on them and give you a chance to read them.


Transition tax case - motion for reconsideration.

We filed a motion asking for the judge to reconsider. The motion raises a large number of mistakes the judge made, particularly with regard to his analysis of what the Transition tax and 962 are all about. The chances of winning this motion are not great BUT the purpose of the motion is also to make sure we raise all these issues now so we can use them in our appeal.


Motion:

https://drive.google.com/file/d/1V1p5YMNEwQXVpwGpt7BwXvyfiT8xyRMY/view?usp=sharing



GILTI case - supplemental brief to government's motion for reconsideration

The GILTI judge asked the sides to each submit a brief summarizing the Transition tax judgement and to explain why this is or is not relevant to the GILTI case. Obviously an important brief. We have addressed the issues the Transition judge raised and are confident.

Motion:

https://drive.google.com/file/d/1i61CcOULv0veJaxSHB9QWG8ax_sfbFWM/view?usp=sharing


Important Exhibit:

https://drive.google.com/file/d/1QHhYHH_BYS7-IOa5h9qVKjF1sm1NTrvo/view?usp=sharing


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