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 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