The IRS Commissioner’s decision to allow double-taxation on revenues already taxed overseas (in the UK, in this case) creates a split in U.S. Courts of Appeals circuits and sends shockwaves through the business community.
SLF, joined by CATO Institute and the Goldwater Institute, submits an important amicus brief on petition for writ of certiorari to the U.S. Supreme Court pointing out that the IRS has overstepped its administrative authority, decades of decisions in the other direction, and flouted important case law by ruling in Orwellian doublespeak that certain revenue should be subject to double-taxation without credit given for foreign taxes paid - what the U.S. Supreme Court has described as the purpose behind existing federal law “to mitigate the evil of double taxation.”
SLF amicus briefs to the U.S. Supreme Court are regularly cited in the high court’s decision on critical issues, including taxation. PPL Corp. and Subsidiaries v. Commissioner of Internal Revenue, Case No. 12-43