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
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships. The guidance, summarized below,...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
10/10/2023
/ Artificial Intelligence ,
Audits ,
Enforcement ,
General-Business ,
Hedge Funds ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Master Limited Partnerships ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Real Estate Transactions ,
Tax Litigation
Large partnership audits are a cornerstone of the IRS’ revamped enforcement priorities. As part of its Large Partnership Compliance program, the agency recently announced that it is rolling out audits of 75 large partnerships...more
The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more
12/29/2022
/ Accountants ,
Alternative Minimum Tax ,
Attorney-Client Privilege ,
Confidential Communications ,
Continuing Legal Education ,
Corporate Taxes ,
Events ,
GAAP ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Audits ,
Tax Liability
In his April 28, 2021 address, President Biden asked Congress to provide $80 billion of extra funding for the Internal Revenue Service (“IRS”) over the next decade. While the timing and amount of any additional funding are...more
High-income individuals and private foundations will have more to worry about on July 15 than just filing tax returns and making tax payments. On that day, the IRS will open the floodgates on examinations of the income tax...more
But Congress may act to enable taxpayers to deduct expenses paid with PPP loan proceeds
On April 30, 2020, the IRS released guidance disallowing deductions for otherwise deductible expenses if payment of the expense...more
In an attempt to improve the quality of transfer pricing documentation, the IRS has released transfer pricing FAQs encouraging taxpayers to “step up their game”...more
The roughly $2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act) passed on March 27, 2020 includes temporary modifications to the Internal Revenue Code intended to provide economic relief and increased...more
The IRS has issued guidance allowing BBA partnerships to claim tax benefits provided under the CARES Act immediately, placing such partnerships on similar footing as corporations...more