News & Analysis as of

Supreme Court of the United States › Internal Revenue Code (IRC) › Administrative Procedure Act

The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary... more +
The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary with only a limited number of cases granted review each term.  The Court is comprised of one chief justice and eight associate justices, who are nominated by the President and confirmed by the Senate to hold lifetime positions. less -
Cadwalader, Wickersham & Taft LLP

Supreme Court Overruling of Chevron Fuels Regulatory Uncertainty

Cadwalader, Wickersham & Taft LLP on

On June 28, the U.S. Supreme Court sent shockwaves through the legal system by overturning one of the foundational precedents of American administrative law.  In Loper Bright Enterprises v. Raimondo, the Court, in a 6-3...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

McDermott Will & Emery on

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

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

Gray Reed

Recent Supreme Court Case Provides Possible Pre-Assessment Judicial Review for Onerous Penalties

Gray Reed on

The Supreme Court’s recent decision in CIC Services, LLC v. Internal Revenue Service may have significantly expanded taxpayers’ ability to obtain immediate injunctive relief against onerous tax reporting requirement....more

Latham & Watkins LLP

US Supreme Court Allows Challenge to IRS Rule to Go Forward Despite Anti-Injunction Act

Latham & Watkins LLP on

The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations. Key Points: ..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more

Holland & Knight LLP

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

Holland & Knight LLP on

The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more

McDermott Will & Emery

Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime

McDermott Will & Emery on

In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more

Eversheds Sutherland (US) LLP

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC - The Anti-Injunction Act has its limits

Eversheds Sutherland (US) LLP on

On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more

Alston & Bird

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

Alston & Bird on

Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more

McDermott Will & Emery

Supreme Court Tackles Tax-Related Cases

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The United States Supreme Court has picked up the pace this week, already issuing eight regular opinions and four opinions relating to orders as of today. We discuss the tax-related items here. In Rodriguez v. FDIC, the...more

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