Taxes

Gifting sounds nice in theory, but it can be complicated in practice, particularly when it comes to transfers by or to foreign persons. The Internal Revenue Service (“IRS”), suspecting wrongdoers at every turn, has been busy recently applying pressure in the international realm. This has triggered several court decisions, two of which are discussed here,
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The Tax Court’s new opinion deciding the blocked income question raised in Coca-Cola v. Commissioner, T.C. Memo. 2023-135, suggests that Coca-Cola’s prospects of eventual success are dim, whether the blocked income regulations are upheld on appeal or not. Judge Albert Lauber’s November 8 supplemental opinion in Coca-Cola is the epilogue to the landmark 2020 opinion
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