Introduction U.S. citizens are generally taxed on worldwide income. To alleviate double taxation, the Internal Revenue Code (IRC) offers a credit for foreign taxes paid.

In Fuentes v. Empire Nissan, Inc., a discharged employee sued in a Superior Court, arguing that the arbitration agreement was unconscionable. The trial court sided

In 2010, Congress codified the economic substance doctrine in § 7701(o) of the Internal Revenue Code.[1] Patel v. Commissioner “is the Court’s first opportunity to

One of the most important rights a taxpayer enjoys is the opportunity of judicial review before a “deficiency” is “assessed.”[1] “Assessment is the formal recording

Section 6038 generally requires a U.S. person to file an information return regarding each foreign business the U.S. person controls. For example, Form 5471 is

Chinese residents are taxed on their worldwide income by China. Nonresidents are taxed by China only on income sourced to China. Offshore trusts have become

Enforcement, Credits, and Apportionment Summary Welcome to the fifth and final part of this series on Proposition 40, “The 2026 Billionaire Tax Act.”[1] This part