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Internal Revenue Service Chevron Deference Corporate Taxes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
McDermott Will & Emery

FedEx Defeats Government’s Loper Bright Gambit

McDermott Will & Emery on

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

Crunched Credit

The Administrative Illuminati in Pursuit of Command and Control (Or the Unmentionable in Hot Pursuit of the Inedible with...

Crunched Credit on

The way we regulate rarely works terribly well for the regulator or the regulated.  Yet, we keep doing it the same way…a subspecies of insanity to be sure.   As an example, has anyone out there in CRE land taken a gander at...more

DLA Piper

REIT Tax News - October 2024

DLA Piper on

Welcome to the October 2024 issue of REIT Tax News. Below, we take a look at five developments to read about in less than five minutes. 1. Loper Bright standard takes hold in Varian Medical case - In the landmark case of...more

Sullivan & Worcester

The Most Draconian Tax Rule in the World

Sullivan & Worcester on

In today's blog, we look at the most draconian tax rule in the world and examine whether the rule is valid. In addition, we examine a recent United States Tax Court case where the court upheld this draconian rule against a UK...more

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

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