Mr. Cope monitors the development of U.S. tax law daily through postings on government websites, daily tax publications, monthly tax journals, tax newsletters, tax conferences and meetings of professionals organizations in New York and Washington. Each month he publishes the Tax Insights Blog, which describes and analyzes significant U.S. tax developments (e.g., judicial decisions, regulations, proposed tax legislation) having cross-border tax consequences. The blog's content should be of interest to U.S. businesses with foreign operations and businesses headquarted outside the United States with U.S. investments or U.S. operations.
Visitors to this website may subscribe to the blog via the RSS link below.
Court Rules for Insider Trader Seeking Deduction for Taxed Income Later Forfeited
On March 12, 2014 the Court of Federal Claims granted a motion for partial summary judgment in favor of the taxpayers in the case of Joseph P. Nacchio and Anne M. Esker v. United States. The taxpayers have filed suit seeking a credit pursuant to section 1341 of the Code. That section allows a credit for amounts included in income in a prior year under “a claim of right” when that income is later determined not to be the taxpayer’s. The amounts at stake in the case are significant and the facts are unusual because the taxable income at issue was derived from criminal activity.