Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
7/16/2025
/ Business Taxes ,
Compensation ,
Corporate Taxes ,
Employee Benefits ,
Executive Compensation ,
Federal Budget ,
Federal Taxes ,
Internal Revenue Code (IRC) ,
Loper Bright Enterprises v Raimondo ,
New Legislation ,
SCOTUS ,
Tax Court ,
Tax Reform ,
Taxation ,
Trump Administration
On July 2, 2025, the Tax Court issued its unanimous reviewed opinion in JM Assets, LP v. Commissioner, 165 T.C. 1. It held that the Service did not timely issue a final partnership adjustment (FPA) to JM Assets, LP (JM...more
7/11/2025
/ Administrative Authority ,
Final Rules ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
Loper Bright Enterprises v Raimondo ,
Regulatory Agencies ,
SCOTUS ,
Statutory Interpretation ,
Tax Court ,
Taxation
On November 5, 2024, Judge Goeke of the United States Tax Court issued an order granting the petitioners’ Motion for Reconsideration of Findings (Motion) in Schwarz v. Commissioner. On May 13, 2024, the Tax Court released...more
On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more
8/14/2024
/ Appeals ,
Chevron Deference ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Regulatory Authority ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Statutory Interpretation ,
U.S. Treasury