Current Articles

• OZONE ALCHEMY: Turning Net 1231 Gains Into Gross 1231 Gains (And Losses)
  By Blake Christian
  Key Takeaways Treasury and IRS initially struggled regarding how to deal with IRC Section 1231 gains and losses in the context of the OZ program; however, the final OZ Regulations ended up being […]
• Taxing The American Emigrant: Part 1
  By Laura Snyder
  LAURA SNYDER∗ Abstract American emigrants face many consequences from the extraterritorial ap-plication of U.S. taxation and banking policies. Their names, addresses, and Social Security numbers are […]
• But, Your Honor, There’s A Coronavirus Pandemic, Part II—United States v. Ishmael
  By Zachary Montgomery
  In a previous blog, I provided an overview of Section 3582(c) with respect to the modification of prison terms. In addition, I looked at two recent cases (United States v. Higa [Hawaii] & United […]
• States Have Benefited From The Wayfair Decision
  By Monika Miles
  Over the last several years, the U.S. Supreme Court’s decision in South Dakota v. Wayfair has led to rule changes regarding online sales tax in almost every state in the country. The ruling, that […]
• A Simple Regulatory Fix For The Problem Of US Citizenship Taxation
  By John Richardson
  https://twitter.com/ExpatriationLaw/status/1354376306172030977 Background In 2016 I first made the suggestion that citizenship-based taxation could be changed through Treasury regulation. In October […]