Loper Bright's Impact on Foreign Taxation: Challenges to Existing IRS and Treasury Regulations
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will review the potential impact of the Supreme Court's decision in Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244, 2273 (2024) on global taxpayers. Our panel of international tax advisers will examine the decision and the history of courts' deference to agency interpretations and suggest appropriate strategies for taxpayers as they consider how the new standard may impact existing rules and regulations. They will point out regulations that are most likely to be challenged under the new standard.
Outline
- Introduction
- Background
- The Loper Bright decision
- Implications
- IRS: impact on IRS and Treasury regulations
- Taxpayers: strategies and challenges
- Future drafting of law
- Examples of regulations that might be challenged
Benefits
The webinar will cover these and other critical issues:
- Actions international taxpayers should consider after the SCOTUS Loper Bright decision
- Examples of regulations that might be challenged
- Possible changes in IRS settlement approaches
- Effect on litigation and refund claims
Faculty
Surbhi Bordia
Partner
Armanino Advisory
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax... | Read More
Ms. Bordia has over 15 years of extensive public accounting experience on addressing various complex transaction tax and international tax issues. She has assisted several clients on transaction tax related matters including but not limited to taxable and non-taxable U.S. and cross-border reorganizations, liquidations, redemptions, spin-offs, dispositions, debt restructurings, due diligence projects and in application of consolidated return regulations. Ms. Bordia has hands on experience in international tax restructuring, IP migration planning, legal entity rationalizations and integrations post mergers and acquisitions. Her areas of expertise include but is not limited to GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credit, subpart F, withholding tax, investment in US property, FX gains and losses, treaty related issues, outbound transfers, permanent establishment and profit attribution rules etc. Before joining Armanino, Ms. Bordia worked at PwC, KPMG and Deloitte. She received her MBA at Haas School of Business at UC Berkeley, International Tax Certificate from Golden Gate University, Masters in Business and Bachelor of Commerce from Jai Narain Vyas University, India.
Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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Nick Zemil
Director
PwC
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on... | Read More
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on outbound transactions. Prior to joining PwC's Washington National Tax Services group, he was an associate at an international law firm where his practice focused on cross-border tax controversy issues ranging from the audit stage through litigation. While attending the University of Virginia School of Law, Mr. Zemil was on the editorial board of and was a contributor to the Virginia Tax Review.
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