Maria Jones was quoted regarding the DC Circuit's ruling on the application of the IRC section 4371 excise tax to wholly foreign retrocession transactions. Jones said she saw no room for the IRS to continue its cascading tax approach to wholly foreign retrocessions based on the DC Circuit's decision. "Sometimes when a case comes out, the decision can provide unexpected new legal arguments for the IRS or taxpayers to use in other circumstances," Jones said. "This is not one of those decisions. The court got it just right, and there are no big surprises here." She added that the IRS is also unlikely to successfully petition to the U.S. Supreme Court to review the dispute, since there is no circuit split on the issue.