News & Analysis as of

Loper Bright Enterprises v Raimondo Internal Revenue Code (IRC) Appeals

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

Holland & Knight LLP

Final Regulations on IRS Appeals Issued

Holland & Knight LLP on

In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more

Proskauer Rose LLP

Wealth Management Update - January 2025

Proskauer Rose LLP on

The January 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.2%, an increase from the December 2024 rate of 5.0%. The January applicable federal rate (“AFR”) for use with...more

Eversheds Sutherland (US) LLP

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

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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