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.
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Government Prevails in Money Market Stripping Case
On May 9, 2014, the U.S. Court of Federal Claims issued a decision in favor of the government in Principal Life Ins. Co. v. United States
. The case considers the taxation of a dividend stripping transaction involving shares of a money market fund. The case is significant because it clarifies when and how tax basis is allocated when rights to receive future dividends are separated from the underlying shares.