# Monte Silver’s legal challenge to the IRS transition tax regulations



## underation (Oct 25, 2018)

The IRS regulations interpret TCJA retroactive transition tax and “deemed distribution” provisions in such a way as to hit small foreign corporations even worse than multinational tech companies, if the corporation is owned by a US expat.

An Israeli expat has had the excellent gumption to mount a legal challenge to the regulations; the IRS filed a motion to dismiss; Mr Silver has filed a counter-motion.

Law360 has published an article commenting on the IRS’s motion to dismiss. 

https://mobile.twitter.com/MonteSilver1/status/1151768411594211328

(All of the above is according to my understanding. IANAL)


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