The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more
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