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U.S. Tax Law After Loper Bright and Corner Post: Key Issues and Ramifications for IRS, Treasury, and Taxpayers

Recording of a 90-minute premium CLE/CPE video webinar with Q&A

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Conducted on Wednesday, October 2, 2024

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This CLE/CPE webinar will provide guidance to tax counsel and advisers on notable U.S. Supreme Court decisions in Loper Bright Enterprises v. Raimondo and Corner Post Inc. v. Board of Governors of the Federal Reserve System. The panel will discuss the significant impact these decisions will have on IRS, Treasury, and other agency policies and the effect the Court's decisions will have on rulemaking, adjudication, and litigation in the tax law context.

Description

The U.S. Supreme Court decisions in Loper Bright Enterprises v. Raimondo and Corner Post v. Board of Governors of the Federal Reserve System will have a significant impact on IRS and Treasury rulemaking, rule implementation, and legal challenges to federal tax rules. Attorneys assisting clients with tax law matters must understand the implications of these rulings and how their clients may be affected.

Loper Bright overruled the Chevron doctrine which has served as the two-step framework for federal courts in deciding disputes between federal agencies and private parties challenging agency regulations for decades. Under Chevron, courts would first ask whether Congress had "directly spoken to the precise question at issue" in the statute. If not, the courts were required to defer to the agency's interpretation as long as it was reasonable. Loper Bright has now put the task of interpreting statutory provisions back into the hands of federal courts.

Corner Post has increased agency exposure to suits by clarifying when the statute of limitations period begins during which rules may be challenged. The Court held that the six-year statute of limitations for suits against the federal government begins to run only once the plaintiff has been injured, a significant change from the prior stance that the six-year period began once the rule was published. Therefore, entities formed within the last six years may challenge regulations that have stood for decades.

Listen as our expert panel guides practitioners through the recent Loper Bright and Corner Post decisions and discusses the impact on tax regulations and litigation as well as potential new challenges to longstanding tax regulations.

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Outline

  1. Introduction: a brief history of the Chevron deference doctrine
  2. Loper Bright v. Raimondo
  3. Corner Post v. Board of Governors of the Federal Reserve System
  4. Legislative and regulatory effect
  5. Regulatory challenges and litigation
  6. Practitioner takeaways

Benefits

The panel will review these and other important issues:

  • How will Loper Bright impact tax regulations and litigation?
  • What effect will Corner Post have on litigation challenging agency rules?
  • How may the decisions affect regulatory rulemaking?
  • What is the potential impact of the decisions on taxpayers?

Faculty

Dawson, James
James (Jim) Dawson

Partner
Holland & Knight

Mr. Dawson is a highly experienced tax litigator and business advisor with extensive knowledge resolving Internal...  |  Read More

Rizek, Christopher
Christopher S. Rizek

Partner
Holland & Knight

Mr. Rizek is a tax attorney in Holland & Knight's Washington, D.C., office. He represents taxpayers in all...  |  Read More

Vanderhoef, Chad
Chad M. Vanderhoef

Partner
Holland & Knight

Mr. Vanderhoef is a tax attorney based in Holland & Knight's Tampa office, where he focuses his practice...  |  Read More

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Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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