The Supreme Court of the United States (“SCOTUS”) has overturned the tariffs imposed by the Trump Administration under the International Emergency Economic Powers Act but did not decide on tariff refunds. As the world awaits...more
Over the past year, the Trump administration’s reciprocal tariffs, imposed under the International Emergency Economic Powers Act, have absorbed media and market attention while the world awaits a US Supreme Court decision on...more
2/5/2026
/ Constitutional Challenges ,
Importers ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
SCOTUS ,
Section 232 ,
Section 301 ,
Separation of Powers ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
Trade Relations ,
Trump Administration ,
US Trade Policies
Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more
11/20/2025
/ Fraud ,
Internal Revenue Code (IRC) ,
Investigations ,
IRS ,
Penalties ,
Statute of Limitations ,
Tax Assessment ,
Tax Audits ,
Tax Court ,
Tax Deductions ,
Tax Fraud ,
Tax Liability ,
Tax Litigation ,
Tax Planning
The Supreme Court held a marathon, nearly 3-hour oral argument yesterday, in what could be the most economically-impactful cases this Term: Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections (the “Tariff...more
11/7/2025
/ Constitutional Challenges ,
Customs and Border Protection ,
Foreign Policy ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Non-Delegation Doctrine ,
Oral Argument ,
Risk Management ,
SCOTUS ,
Supply Chain ,
Tariffs ,
Trump Administration ,
US Trade Policies
Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more
8/8/2025
/ Compliance ,
Enforcement Actions ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Audits ,
Tax Fraud ,
Tax Liability ,
Tax Returns ,
Taxation ,
Underpayment
Since President Donald Trump took office for his second term, the tariff landscape has changed dramatically. Trump is the first US president to exercise his authority under the International Emergency Economic Powers Act...more
7/15/2025
/ CFIUS ,
China ,
Customs ,
Exports ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Tariffs ,
Trade Policy ,
Trade Relations ,
Trump Administration ,
US Trade Policies
The opening days of the 119th U.S. Congress have been marked with congressional action under the Congressional Review Act (CRA) to potentially invalidate regulations that were issued by the Internal Revenue Service (IRS) in...more
As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more
For more than twenty years, the North American Free Trade Agreement (“NAFTA”), and later, the United States‑Mexico-Canada Agreement (“USMCA”), have facilitated cross-border trade and investment among the United States,...more
2/13/2025
/ Canada ,
Energy Policy ,
Energy Sector ,
Executive Orders ,
Imports ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
NAFTA ,
Tariffs ,
Trump Administration ,
United States-Mexico-Canada Agreement (USMCA) ,
US Trade Policies
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more
1/14/2025
/ Compliance ,
Congressional Review Act ,
Disclosure Requirements ,
Final Rules ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Reporting Requirements ,
Tax Planning ,
Tax Returns ,
Taxation ,
U.S. Treasury
The IRS Independent Office of Appeals has renewed its focus on alternative dispute resolution (ADR). In this article, V&E counsel Stephen Josey examines the ADR program and dives into how the agency can tweak its mediation...more