Weil Tax BLOG - Feed https://tax.weil.com/contributor/theo-agbi/ Views and developments from the Tax Department at Weil Fri, 29 May 2026 16:24:17 +0000 hourly 1 Moore of the Same: “The Constitution does not require Fiscal Calamity…” The Supreme Court’s Scathing Rejection of the Moores’ Constitutional Tax Challenge https://tax.weil.com/features/moore-of-the-same-the-constitution-does-not-require-fiscal-calamity-the-supreme-courts-scathing-rejection-of-the-moores-constitutional-tax-challenge/ Fri, 21 Jun 2024 15:05:15 +0000 Devon Bodoh Joseph Pari Alfonso Dulcey Grant Solomon Theo Agbi https://tax.weil.com/?p=2256 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 (the “TCJA”) mandatory repatriation tax (“MRT”) under Section 965 of the Internal Revenue Code1 does not violate the Direct Tax Clause of the Constitution. Congress enacted the MRT as part of

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]]> Crypto Broker Reporting Regulations Should Avoid Mismatch Risk https://tax.weil.com/features/crypto-broker-reporting-regulations-should-avoid-mismatch-risk/ Tue, 21 May 2024 19:18:57 +0000 Devon Bodoh Theo Agbi Carlos Parra https://tax.weil.com/?p=2219 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. Read more

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]]> Notice 2024-16: Guidance Allowing for Basis Adjustments to CFC Stock Transferred in Inbound Nonrecognition Transactions https://tax.weil.com/features/notice-2024-16-guidance-allowing-for-basis-adjustments-to-cfc-stock-transferred-in-inbound-nonrecognition-transactions/ Thu, 04 Jan 2024 15:56:19 +0000 Devon Bodoh Alfonso Dulcey Theo Agbi Marvin Zanders https://tax.weil.com/?p=2093 Introduction On December 28, 2023, the Internal Revenue Service (“IRS”) released Notice 2024-16 (the “Notice”) announcing the intent of the Treasury Department (“Treasury”) and the IRS to issue proposed regulations addressing basis consequences under Section 961(c)1 relating to certain inbound liquidations and asset reorganizations (collectively “Inbound Non-recognition Transactions”) whereby a U.S. corporation (the “Domestic Acquiring

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]]> Examining the U.S. – Chile Tax Treaty https://tax.weil.com/insights/examining-the-u-s-chile-tax-treaty/ Wed, 03 Jan 2024 15:52:54 +0000 Devon Bodoh Alfonso Dulcey Allen Lalanne Theo Agbi https://tax.weil.com/?p=2088 Introduction 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 (the “Treaty”). 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

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]]> IRS Issues Guidance on Foreign Tax Credit and Global Minimum Tax https://tax.weil.com/latest-thinking/irs-issues-guidance-on-foreign-tax-credit-and-global-minimum-tax/ Thu, 21 Dec 2023 18:37:51 +0000 Devon Bodoh Jonathan Vita Theo Agbi https://tax.weil.com/?p=2071 On December 11, 2023, the Internal Revenue Service (“IRS”) released Notice 2023-80 (the “Notice”) establishing the intentions of the Treasury Department (“Treasury”) and the IRS to issue proposed regulations addressing the application of the foreign tax credit (“FTC”) rules and dual consolidated loss (“DCL”) rules with respect to certain  taxes under the Pillar Two global

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