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Foreign Earnings Tax Rules Hearing Focuses on Ability to Sue

March 15, 2021, 9:48 PM

Oral arguments in a lawsuit challenging the validity of rules implementing part of the 2017 tax overhaul focused heavily on whether the plaintiffs are in the right position to bring the challenge.

The questions were raised Monday during oral arguments at the U.S. District Court for the District of Columbia, which has been tasked with deciding whether Treasury violated multiple statutes in the way it issued rules implementing tax code Section 965‘s transition tax, passed through the 2017 law. The tax treats otherwise-untaxed foreign earnings of U.S. shareholders of certain foreign corporations as if the earnings had been brought ...

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