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).

Photo of Irina Pisareva Irina Pisareva

Irina specializes in tax structuring of cross-border debt and equity transactions, alternative investment funds and investment management companies, international taxation of securities and private capital. She is also the editor of The Tax Trotter (http://www.taxtrotter.com/) , a blog that provides tax

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Irina specializes in tax structuring of cross-border debt and equity transactions, alternative investment funds and investment management companies, international taxation of securities and private capital. She is also the editor of The Tax Trotter (http://www.taxtrotter.com/) , a blog that provides tax insights from around the world.

Before joining Sullivan, Irina was a partner at EY where she served as a lead international tax service partner for private equity, credit and multi-strategy asset management firms with $2bln to $300+ bill AUM. In addition to her structuring and transactional practice, Irina developed programs to reduce organizational tax risk and optimize global effective tax rate for companies and family offices.

Irina’s full biography may be found here (https://www.sullivanlaw.com/professionals-Irina-Pisareva.html) .

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