News & Analysis as of

Loper Bright Enterprises v Raimondo Supreme Court of the United States Tax Court

Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 14, 2025

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

Eversheds Sutherland (US) LLP

Tax Court holds final partnership adjustment untimely, invalidates conflicting regulation

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

Eversheds Sutherland (US) LLP

Tax Court update post-Chevron

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

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

Jones Day on

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

McDermott Will & Emery

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

McDermott Will & Emery on

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

Fenwick & West LLP

Five Tax Cases that May Impact Your Business 2024

Fenwick & West LLP on

The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more

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