Tax Court and Court of Federal Claims reject GILTI Effective-date-fix Regulations In Upholding Deductions

In two recent decisions, Siemens Medical Solutions USA, Inc. & Consolidated Subsidiaries v. Commissioner, 167 T.C. No. 5 (July 15, 2026), and Keysight Technologies, Inc. v. United States, No. 25-137 (Fed. Cl. July 2, 2026), the US Tax Court and the Court of Federal Claims rejected Treasury Regulations that purported to override the Congressionally-mandated effective dates set for various TCJA international tax provisions.... By: Eversheds Sutherland (US) LLP