The high court’s decision in Loper Bright seems likely to effect a sea change in administrative law—but the practical impact (if any) it will have on tax regulations in particular remains to be seen.
On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets.
The recent private letter ruling is a step in the right direction for the securitization of CPACE assets.
The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets.
The UK’s Upper Tribunal decision in Burlington confirmed that the anti-abuse provision in the UK-Ireland double tax treaty requires consideration of all the circumstances of the case.
In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax ("MRT"), saving a significant portion of the current tax code for now. The question in front of the Court was whether the Constitution requires income to be realized before it may be taxed and, if so, whether the realization requirement was met. The Court found that the income in question had in fact been realized, avoiding a broader ruling on whether realization is always required to tax income.