International Firm Allowed to Proceed With GILTI Rules Challenge

An Israeli businessman fighting global intangible low-taxed income regulations scored a partial win after a federal judge in Washington, DC, allowed his company to proceed with the case.

Judge Colleen Kollar-Kotelly of the US District Court for the District of Columbia Wednesday dismissed Monte Silver’s individual claim against the IRS over its implementation of the GILTI tax without considering the rules’ impact on small businesses. But his law firm, Monte Silver Ltd., may proceed with that claim, she said.

The business met its burden of proving harm from the GILTI tax provisions, an amendment to IRC Section 951A via the ...