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Regulatory Requirements › Government Agencies › Internal Revenue Service

Orrick, Herrington & Sutcliffe LLP

Increasing Frequency of Incorrect IRS Notices to Tax-Exempt Bond Issuers Raises Concerns

Orrick, Herrington & Sutcliffe LLP on

In recent months, issuers of tax-exempt bonds have been facing an unexpected challenge: incorrect notices from the Internal Revenue Service (IRS) claiming that their Forms 8038 are being filed without the required signature....more

McDermott Will & Schulte

FedEx Defeats Government’s Loper Bright Gambit

McDermott Will & Schulte 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

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

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

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

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

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

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