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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Court of Federal Claims Rules for Mexican National in Refund Suit
August 2014
The case of Maria Esther Montiel v. United States (“Monteil”) considers the question of how to determine the limitation period for filing a refund claim when a nonresident alien erroneously files an original tax return as a U.S. resident and later determines that she should have filed as a nonresident alien. As discussed below, the Court of Federal Claims concluded that there was a triable issue as to whether it had subject matter jurisdiction on the facts in Montiel.
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IRS Releases Facts Sheet on Its Offshore Voluntary Disclosure Program
June 2014
In June 2014, the IRS released a fact sheet showing the results of its offshore voluntary disclosure program. The program, which remains in effect today, has produced $6.5 billion in tax revenue from approximately 45,000 taxpayers since its inception in 2009.
