Archive for the Tax Court Category

District Court Nixes Constitutional Challenge To Income Tax Return And FBAR Filing Requirements

A federal district court has rejected a taxpayer’s argument that statutes and regs requiring U.K. citizens with U.S. permanent resident status to file income tax returns and Reports of Foreign Bank and Financial Accounts (FBARs), when read with the U.S.-U.K tax treaty, are so ambiguous that they…

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First Circuit Finds Puerto Rico’s Corporate AMT Unconstitutional

Affirming a federal district court, the First Circuit Court of Appeals has struck down parts of Puerto Rico’s corporate alternative minimum tax (AMT). The court was not persuaded that the AMT did not discriminate against interstate commerce. The First Circuit Court of Appeals, affirming a U.S. district…

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President of Company held as Responsible Person Liable for Unpaid Withholding Taxes

The case described below is a perfect example why it is extremely important to be vigilant about the people you hire and the intricacies of how your business is being ran, regardless if you are willfully involved in the illegal act or not. You don’t ever want…

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