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05.08.2026

Firm Publication

Tax Court Applies the Economic Substance Doctrine to a Section 743(b) Adjustment in Otay

Tax Alert

05.08.2026

Firm Publication

Second Circuit Clarifies and Simplifies IRS's Authority to Administratively Assess International Information Reporting Penalties

Tax Alert

11.14.2025

Firm Publication

Tax Court Decision in Patel Clarifies Scope of the Economic Substance Doctrine

Tax Alert

10.10.2025

Firm Publication

District Court Strictly Applies Repeal of Subpart F Downward Attribution Rules in Altria

Tax Alert

10.10.2025

Firm Publication

Treasury Announces PAM Pilot Program Reassigning Cases to New Appeals Teams

Tax Alert

06.13.2025

Firm Publication

Deregulatory Update: Notice 2025-19 Triggers a Significant Increase in Input on the Priority Guidance Plan

Tax Alert

05.13.2025

Firm Publication

The Growing Impact of Loper Bright on the Tax Court

Tax Alert

05.02.2025

External Publication

Administration Order to Rescind Guidance Raises Questions Under the APA

03.12.2025

Firm Publication

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

Tax Alert

02.13.2025

Firm Publication

IRS Announces ADR Pilot Programs

Tax Alert

01.16.2025

Firm Publication

Tax Court Rejects IRS Inventory Argument in Easement Case

Tax Alert

01.16.2025

Firm Publication

IRS Releases Draft Instructions for Revised R&E Credit Form

Tax Alert

01.16.2025

Firm Publication

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

Tax Alert

12.12.2024

Firm Publication

CHIPS Act Grant Agreements Not Long-Term Contracts

Tax Alert

12.12.2024

Firm Publication

Tax Court Again Holds IRS Lacks Authority to Assess Foreign Reporting Penalty

Tax Alert

12.12.2024

Firm Publication

IRS Extends Transition Period for R&D Credit Refund Claims

Tax Alert

11.04.2024

Firm Publication

Final Rules for CHIPS Tax Credit Clarify Eligible Investments and Recapture Rules

Tax Alert

11.04.2024

Firm Publication

IRS and Treasury Issue Final Syndicated Conservation Easement Regulations

Tax Alert

10.07.2024

Firm Publication

Tax Court Requests Amicus Briefs on ESD in Patel

Tax Alert

10.07.2024

Firm Publication

IRS and Treasury Release Long-awaited CAMT Proposed Regulations: Select International Tax Considerations

Tax Alert

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publications

Tax Court Applies the Economic Substance Doctrine to a Section 743(b) Adjustment in Otay

Second Circuit Clarifies and Simplifies IRS's Authority to Administratively Assess International Information Reporting Penalties

Tax Court Decision in Patel Clarifies Scope of the Economic Substance Doctrine

District Court Strictly Applies Repeal of Subpart F Downward Attribution Rules in Altria

Treasury Announces PAM Pilot Program Reassigning Cases to New Appeals Teams

Deregulatory Update: Notice 2025-19 Triggers a Significant Increase in Input on the Priority Guidance Plan

The Growing Impact of Loper Bright on the Tax Court

Administration Order to Rescind Guidance Raises Questions Under the APA

District Court Confirms Prior FedEx Ruling Is Unaffected by Loper Bright and Rejects New Argument from the DOJ

IRS Announces ADR Pilot Programs

Tax Court Rejects IRS Inventory Argument in Easement Case

IRS Releases Draft Instructions for Revised R&E Credit Form

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

CHIPS Act Grant Agreements Not Long-Term Contracts

Tax Court Again Holds IRS Lacks Authority to Assess Foreign Reporting Penalty

IRS Extends Transition Period for R&D Credit Refund Claims

Final Rules for CHIPS Tax Credit Clarify Eligible Investments and Recapture Rules

IRS and Treasury Issue Final Syndicated Conservation Easement Regulations

Tax Court Requests Amicus Briefs on ESD in Patel

IRS and Treasury Release Long-awaited CAMT Proposed Regulations: Select International Tax Considerations

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