Overview
Bloomberg Law quoted Lauren Azebu in an article titled "Three International Tax Cases Practitioners Must Watch in 2025." The article highlights three international tax cases that federal courts will decide that will influence how tax planners handle uncertainty in the upcoming years.
One case in particular, Altria Group Inc's $105 million refund suit, has the potential to determine whether certain US taxpayers must impute income resulting from foreign stock ownership. Altria's stance is that its small equity interest in Anheuser-Busch Inbev (ABI) wasn't large enough to necessitate including ABI foreign subsidiary earnings when calculating taxable income. According to Azebu, "the repeal of IRC section 958(b)(4), which prevented downward attribution of foreign-owned stock to a US taxpayer, caused many companies to become controlled foreign corporations that weren’t previously treated as such."
According to the government, the Supreme Court's Moore v. United States decision undermines Altria's request for summary judgement, "but if Altria prevails, minority US shareholders of CFCs that aren't majority-US owned may see reduced tax liability," Azebu continued.
Read the full article in the Bloomberg Law. (Subscription required)
