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January 22, 2024
The certiorari application in Connelly v. Internal Revenue Service, 70 F.4th 412 (8th Cir. 2023), was granted by the Supreme Court on December 13, 2023. It commences as follows...
March 25, 2022
In today’s rapidly changing tax environment, it is important to be aware of all relevant tax developments. In the past months, several new tax rules…
December 2, 2021
When a Mosotho or a Sesotho speaker says "stay together," they usually mean "live together." By this terminology, the Inclusive Framework of 137 countries that agreed in October...
February 17, 2021
U.S. Cross-border Tax Reform and the Cautionary Tale of GILTI Daniel Bunn Key Findings The U.S. joined many other developed nations in adopting territorial provisions and anti-base erosion rules as part of the 2017 tax reform. One major piece of that reform, that is not typical in other territorial systems, is a new definition of currently taxable foreign earnings, Global Intangible Low Tax Income (GILTI), which is taxed at an effective rate of 13.125 percent, with the rate set to increase afte...