The anti-inversion regulations issued by Treasury in 2016 were held unlawful due to lack of a notice-and-comment period under the Administrative Procedure Act (APA). The U.S. District Court for the Western District of Texas concluded that the regulations were unlawfully issued without adherence to the APA’s notice-and-comment requirements. The court stated that, where an agency […]
Written by Kamil Turkmani and Joshua Wu The United States Court of Appeals for the D.C. Circuit recently affirmed the district court’s decision in Maze v. Internal Revenue Service on July 14th, 2017. In citing the Anti-Injunction Act (“AIA”) of 28 U.S.C. §7421(a), the court held that the federal courts lacked subject matter jurisdiction to […]
The IRS released the highly-anticipated proposed regulations for the new partnership audit regime on June 13, 2017. The proposed regulations were released to, but not published in, the Federal Register earlier this year. Congress passed the new rules as part of the Bipartisan Budget Act of 2015 (“BBA”) to repeal and replace the prior unified […]
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