Tax Court, however, disagrees with taxpayer on value of the receivable. In the May 13, 2021, decision in the Estate of Clara M. Morrissette, the U.S. Tax Court (T.C. Memo 2021-60) struck down the Section 2036, 2038, and 2703 arguments put forth by the IRS pertaining to split-dollar receivables; however, Judge Joseph Robert Goeke made significant adjustments to the value of the receivables. Background The IRS issued a $39.4 million deficiency with respect to the estate of Clara M. Morrissette, increasing the fair...

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In this week’s Roar, we’ve got China-Europe freight trains helping the fight against COVID-19, rapidly increasing ocean shipping delays, the industry’s impending peak season, efforts to cut supply chain waste, and the rise of sustainable aviation fuel. First, there’s something interesting happening with the China-Europe freight trains located in the Lianyungang, Jiangsu province. They are not only providing safe and reliable international transportation, but they’re also helping the global fight against the coronavirus pandemic. According to China Daily, they carried 3 million doses...

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On 18 May 2021, the EU Commission published a Communication on Business Taxation for the 21st century (“the Communication”). The Communication sets out both a long-term and a short-term vision to support the EU’s recovery from the COVID-19 pandemic, creates a fair and sustainable EU tax business environment, and takes account of the ongoing work on international corporate tax reform at OECD level. Corporate taxpayers are expected to be significantly impacted by the proposed framework, in particular the new framework for income taxation...

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