Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more
7/19/2024
/ Administrative Authority ,
Administrative Procedure Act ,
Chevron Deference ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Government Agencies ,
IRS ,
Loper Bright Enterprises v Raimondo ,
SCOTUS ,
Statute of Limitations ,
Statutory Interpretation ,
U.S. Treasury
The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more
6/27/2024
/ 16th Amendment ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Moore v US ,
Repatriation ,
SCOTUS ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Revenues
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more
6/3/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties