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Government Agencies Internal Revenue Code (IRC)

Jackson Lewis P.C.

White House Releases America’s AI Action Plan: A Strategic Framework for Innovation, Infrastructure, and Global AI Leadership

Jackson Lewis P.C. on

On July 23, 2025, the White House released America’s AI Action Plan, a comprehensive national strategy designed to strengthen the United States’ position in artificial intelligence through investment in innovation,...more

Foster Swift Collins & Smith

Determining Private Foundation or Public Charity Status under the Support Test

A hypothetical state law for-profit company, which may be a bank, credit union, insurance company, healthcare organization, or other entity (“Company”) intends to establish a charitable organization (“Foundation”) to carry...more

Fox Rothschild LLP

The IRS-ICE Tax Data Sharing Agreement: Practical Considerations

Fox Rothschild LLP on

The IRS and ICE have signed a Memorandum of Understanding (MOU) that allows the IRS to share taxpayer information such as names, addresses, and tax data, with ICE for immigration-related criminal enforcement of individuals...more

Frost Brown Todd

TEFRA Approvals: Considerations for Officeholders When Approving Private Activity Bonds

Frost Brown Todd on

New officeholders often ask us to clarify their responsibilities when it comes to public approval of bonds and the consequences for states and their political subdivisions when they approve bonds as tax-exempt. What follows...more

Eversheds Sutherland (US) LLP

House tax bill proposes changes to information reporting rules

On May 14, 2025, the House Ways and Means Committee approved the “One, Big, Beautiful Bill,” containing the tax provisions destined for the budget reconciliation package. Several of the bill’s provisions would affect...more

King & Spalding

Ways and Means Committee Seeks Information Regarding OPO Activities

King & Spalding on

On April 16, 2025, the Committee on Ways and Means in the U.S. House of Representatives issued a letter to the public requesting information regarding Organ Procurement Organizations (OPOs)—the nonprofit, tax-exempt entities...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Tax Implications of Trump’s Recent Executive Actions

President Donald Trump has issued a series of executive orders with significant tax implications. The moves underscore the administration’s commitment to influencing tax policies, regulatory frameworks and trade practices as...more

McDermott Will & Schulte

FedEx Defeats Government’s Loper Bright Gambit

On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Miller Canfield

Is the Chief of IRS Appeals Constitutionally Appointed?

Miller Canfield on

The United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more

Eversheds Sutherland (US) LLP

In Rawat, DC Circuit construes the Code and regulations without deference, providing an example of statutory and regulatory...

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

Cadwalader, Wickersham & Taft LLP

Supreme Court Overruling of Chevron Fuels Regulatory Uncertainty

On June 28, the U.S. Supreme Court sent shockwaves through the legal system by overturning one of the foundational precedents of American administrative law.  In Loper Bright Enterprises v. Raimondo, the Court, in a 6-3...more

McDermott Will & Schulte

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

Steptoe & Johnson PLLC

The IRS Requirement to Report Settlements With Government Agencies Over $50,000

Steptoe & Johnson PLLC on

As part of the 2017 Tax Cuts and Jobs Act (TCJA), Congress modified the rules governing the deductibility of certain government settlement-related expenses under the Internal Revenue Code (IRC). Effective January 1, 2022,...more

Littler

Settled a Lawsuit with a Government Agency Last Year? Form 1098-F Reporting of Fines and Penalties is Coming Due

Littler on

As part of the 2017 Tax Cuts and Jobs Act (Act), Congress enacted Internal Revenue Code (Code) section 6050X, which requires government agencies (and certain nongovernmental regulatory agencies) to issue information returns...more

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