William Byrnes

Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9…

On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and…

At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations…

The Tax Court issued a nine to eight split decision of six opinions (three in favor and three dissenting) upholding the Service’s 1994 blocked income regulations. Yesterday, February 9, 2023, the Tax…

"It follows that only the national law applicable in the Member State concerned must be taken into account in order to identify the reference system for direct taxation, that identification being…

On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1] If it is a…

On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted…

The U.S. has a highly successful international financial service industry that is important to the U.S. economy, exemplified by, firstly, the international financial centers such as Miami and New…

We commend the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of…