Congratulations to firm partner for his Josh O. Ungerman recognition a Highly Regarded Practitioner by ITR World Tax within Tax Controversy. ITR World Tax is the most comprehensive guide to the world’s leading tax...
The IRS often challenges taxpayers who seek penalty abatements for late-filing penalties, particularly those related to international information returns. Generally, these cases focus on whether the taxpayer can...
Grantor trusts are treated differently from other trusts for federal income tax purposes. Whereas many trusts are respected as separate entities for tax purposes, grantor trusts are disregarded with the grantor (or deemed...
Refund Litigation Continued: Types of Cases
May 28, 2025
This blog builds on prior posts concerning refund litigation. This blog explores the types of tax refund cases that can be brought in the U.S. district courts and the U.S. Court of Federal Claims. Types of Refund Litigation...
The application of U.S. tax laws often turns on the meaning of “residency.” Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens...