On September 12, 2024, the U.S. Treasury Department and the Internal Revenue Service released proposed regulations addressing the application of the corporate alternative minimum tax that...
In Varian, the first case to consider the validity of a Treasury regulation after Loper Bright (in which the U.S. Supreme Court rejected the longstanding Chevron doctrine), the Tax Court ...
In Loper Bright Enterprises v. Raimondo, the Supreme Court overruled Chevron v. NRDC, holding that Chevron deference to an agency’s permissible interpretation of an ambiguous or silent ...
If a taxpayer underpays taxes because of negligence, a penalty of 20% applies. Treasury regulations provide for an exception to this penalty, known as “the reasonable basis exception,...
Background
On November 5, 2017 the International Consortium of Investigative Journalists (“ICIJ”) released the “Paradise Papers,” a collection of 13.4 million files that appear to...
