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 ...

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 ...

At the end of the Tax Court’s 2016 opinion in Medtronic, a short section briefly summarizes and summarily rejects what the opinion describes as the IRS’s “alternative allocation under section 367(d).” ...