Theo Agbi

• Moore of the Same: “The Constitution does not require Fiscal Calamity…” The Supreme Court’s Scathing Rejection of the Moores’ Constitutional Tax Challenge Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman, Grant Solomon and Theo Agbi — June 21, 2024
  On June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, ruling 7-2 that the Tax Cuts and Jobs Act’s mandatory repatriation tax under Section 965 of the Internal Revenue Code does not violate the Direct Tax Clause of the Constitution. Congress enacted the MRT as part of the TCJA’s shift to a more territorial tax system. ...
• Crypto Broker Reporting Regulations Should Avoid Mismatch Risk Blog Post — Tax Blog — By Devon Bodoh, Theo Agbi and Carlos Parra — May 21, 2024
  The IRS’s April 19 release of the draft Form 1099-DA—which will be used to report certain sales and exchanges of digital assets on or after Jan. 1, 2025—may indicate that the IRS is close to finalizing proposed regulations extending information-reporting rules under tax code Section 6045 to crypto and other digital asset transactions. ...
• Notice 2024-16: Guidance Allowing for Basis Adjustments to CFC Stock Transferred in Inbound Nonrecognition Transactions Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman, Theo Agbi and Marvin Zanders — January 04, 2024
  On December 28, 2023, the Internal Revenue Service released Notice 2024-16 announcing the intent of the Treasury Department and the IRS to issue proposed regulations addressing basis consequences under Section 961(c)[1] relating to certain inbound liquidations and asset reorganizations whereby a U.S. corporation acquires from a first-tier controlled foreign corporation all the stock of a second-tier controlled foreign corporation. ...
• Examining the U.S. – Chile Tax Treaty Blog Post — Tax Blog — By Devon Bodoh, Allen Lalanne and Theo Agbi — January 03, 2024
  On December 19, 2023, the United States Department of the Treasury announced the entry into force of the tax treaty between the United States and Chile. Originally signed by the United States and Chile on February 4, 2010, the Treaty was approved by Chilean government in 2015 and was ratified by the United States Senate and signed by President Biden on June 22, 2023. ...
• IRS Issues Guidance on Foreign Tax Credit and Global Minimum Tax Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman, Jonathan Vita and Theo Agbi — December 21, 2023
  On December 11, 2023, the Internal Revenue Service released Notice 2023-80 establishing the intentions of the Treasury Department and the IRS to issue proposed regulations addressing the application of the foreign tax credit rules and dual consolidated loss rules with respect to certain  taxes under the Pillar Two global anti-base erosion rules. ...

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