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International Tax Blog

Andrew Mitchel LLC is a law firm of international tax attorneys with extensive experience in international tax planning.

Anticlimactic Discoveries

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is:

At the heart of the labyrinth, where one might expect to find, if not a Minotaur, then at least an old movie lion, we find high-basis, low-value assets (said to have spawned startling losses) and some B-grade films.

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2017 Second Quarter Published Expatriates – Second Highest Ever

Today the Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency (“expatriated”) during the second quarter of 2017.

The number of published expatriates for the quarter was 1,759, which is the second highest quarterly number ever (second only to the fourth quarter of 2016 which had 2,365 published expatriates).  The number of published expatriates for the first two quarters of 2017 has been 3,072 (1,313 + 1,759).  In the first two quarters of 2017, there has already been more published expatriates than there was for the entire year of 2013 (2,999), which was the first year of explosive growth in the number of published expatriates.

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Tax Court Declines To Follow Rev. Rul. 91-32

Last week, the Tax Court released an important opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, 149 T.C. No. 3, where the court declined to follow Rev. Rul. 91-32.

For more than 25 years the IRS has maintained that gain on a foreign partner’s disposition of an interest in a partnership that conducts business in the U.S.… Read more

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An Unsubstantiated Presumption

Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today’s tax quote is:

The tax collector’s presumption of correctness has a herculean muscularity of Goliathlike reach, but we strike an Achilles’ heel when we find no muscles, no tendons, no ligaments of fact.

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