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Administrative Procedure Act Internal Revenue Service Rulemaking Process

King & Spalding

A Brief Overview of the Federal Rulemaking Process in the United States

King & Spalding on

Since the enactment of the Inflation Reduction Act of 2022 (the “IRA”) in the United States, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have issued notices of proposed regulations...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

Polsinelli on

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

McDermott Will & Emery

Significant Changes In IRS Regulatory Process Ahead

McDermott Will & Emery on

In a previously unannounced development, the U.S. Department of the Treasury issued a policy statement on the tax regulatory process on March 5, 2019, announcing significant changes related to regulations and subregulatory...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Tax Court Invalidates Stock-Based Compensation Amendment in Altera"

On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. §1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more

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