Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
The Liberty Global Inc. v. United States appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business decisions and disrupt...more
The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
The United States Court of Federal Claims recently released two anticipated opinions, Bishop Hill Energy, LLC v. United States and California Ridge Wind Energy, LLC v. United States, which were issued under seal on January 7,...more
On June 20, 2019, the Court of Federal Claims finally released its previously sealed opinions in the companion cases of Bishop Hill Energy, LLC and California Ridge Wind Energy, LLC.1 Both cases are substantially similar,...more