Today, the Tax Trotter is pleased to present an article by her international tax partner Douglas S. Stransky. This article is the first installment in the 2-part post focusing on the Adams Challenge case.
In today's blog, we look at the most draconian tax rule in the world and examine whether the rule is valid. In addition, we examine a recent United States Tax Court case where the court upheld this draconian rule against a UK company, Adams Challenge (UK) Ltd. v. Commissioner, 154 T.C. 37 (2020).