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 January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more
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