June 12, 2025 The Zuch v. Commissioner concerns whether the U.S. Tax Court retains jurisdiction over a case when the underlying IRS collection action is no longer active. The taxpayer initiated proceedings under the Collection Due Process (CDP) rules, but during the case, the IRS resolved the liability, effectively removing the basis for the dispute. The case raised the question of whether the Tax Court can continue to hear a matter once there is no ongoing collection activity. The Court held...

11 April 2024 The Arcomet Group case concerns whether transfer pricing (TP) adjustments should be subject to VAT. The Belgian Tax Authorities increased the taxable profits of Arcomet through TP adjustments and argued that these adjustments also constituted payments for services, thereby triggering VAT. The dispute was brought before the Court of Justice of the European Union (CJEU), which ruled that TP adjustments are not automatically subject to VAT . The Court held that VAT only...

June 20, 2024 The Moore v. United States addressed whether Congress may tax certain corporate earnings attributed to shareholders even when those earnings have not been distributed as cash. The dispute centered on the Mandatory Repatriation Tax introduced by the Tax Cuts and Jobs Act, which required U.S. shareholders of certain foreign corporations to pay tax on accumulated profits held offshore. The taxpayers, Charles and Kathleen Moore, held shares in an Indian company that had reinvested...