As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
1/14/2025
/ Compliance ,
Congressional Review Act ,
Disclosure Requirements ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Planning ,
Tax Returns ,
Taxation ,
U.S. Treasury
In the final decision of the Supreme Court’s term, the Court again considered the Administrative Procedure Act (“APA”). Like earlier decisions this term considering the APA (see here and here), the opinion in Corner Post,...more
In a landmark decision, the Supreme Court has overruled the Chevron doctrine, fundamentally altering the landscape of administrative law and significantly impacting federal tax administration. Six justices, with Chief Justice...more
7/2/2024
/ Administrative Procedure Act ,
Chevron Deference ,
Chevron v NRDC ,
Constitutional Challenges ,
Government Agencies ,
IRS ,
Judicial Authority ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
SCOTUS ,
Statutory Interpretation ,
U.S. Treasury ,
Unconstitutional Condition
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
10/10/2023
/ Artificial Intelligence ,
Audits ,
Enforcement ,
General-Business ,
Hedge Funds ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Master Limited Partnerships ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Real Estate Transactions ,
Tax Litigation
Large partnership audits are a cornerstone of the IRS’ revamped enforcement priorities. As part of its Large Partnership Compliance program, the agency recently announced that it is rolling out audits of 75 large partnerships...more