Briefing Underway in Barnes as Second Circuit Considers Application of...
In Barnes Group v. Commissioner, the Tax Court (Goeke, J.) looked askance at the taxpayer’s strategy for minimizing the tax consequences of a movement of foreign cash to U.S. affiliates. As the...
View ArticleBriefing Completed in Barnes
All of the briefs have now been filed in the Barnes case. The government’s response brief defends the Tax Court’s decision as a run-of-the-mill application of substance over form principles. Quoting...
View ArticleOral Arguments Scheduled in Barnes and MassMutual
As you may have noticed, the blog has been on summer vacation for a variety of reasons. I hope our readers managed some vacation as well and are now eagerly awaiting updates on appellate tax matters....
View ArticleSecond Circuit Summarily Affirms in Barnes
The Second Circuit did not make the parties wait very long to learn the outcome of the Barnes Group’s appeal from the Tax Court’s imposition of dividend treatment on its multi-step transaction that...
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