TaxNotes quoted Andrew Weiner in an article titled “Supreme Court Opens Door to APA Challenges of Older Tax Regs,” published July 2, 2024. The article covers a recent Supreme Court holding in Corner Post Inc. v. Federal Reserve, a nontax case, that the six-year time bar
On July 8, 2024, the ABA Sections of Taxation and Real Property, Trust and Estate submitted comments on the proposed regulations under Internal Revenue Code (IRC) §§ 643(i), 679, 6039F, 6048, and 6677 regarding transactions with foreign trusts and information reporting on transactions with foreign
Michael Sardar was quoted in a July 5, 2024, MarketWatch article titled “What it’s like to be audited by the bigger, better-funded IRS. ‘They are pushing harder now.’” From the article: “With the IRS stepping up enforcement on upper-income taxpayers, Michael Sardar, a partner handling
On July 2, the IRS published proposed regulations providing that the IRS will assess as an underpayment of tax the interest paid to taxpayers on erroneous refunds of the employee retention credit (“ERC”), as well as other employment tax credits, such as the paid sick
On June 28, 2024, transgender activists, legal advocates, and currently unhoused transgender New Yorkers attended a press conference at Foley Square, regarding New York City’s obligation to provide transgender and gender nonconforming (“TGNC”) affirming shelter to unhoused New Yorkers. In a 2021 settlement resolving Mariah Lopez v.
Over the years, the circuits have split on how to interpret the statute of limitations for bringing a facial challenge to a regulation or other agency action under the Administrative Procedure Act (“APA”). Yesterday, in Corner Post, Inc. v. Board of Governors of the Federal
The U.S. Supreme Court today overruled the longstanding Chevron doctrine that for 40 years largely deferred to federal agency regulations in interpreting ambiguities in the law. The landmark decision in Loper Bright Enterprises et al. v. Raimondo, Secretary of Commerce, et al. addressed appeals in Loper Bright
“Superstar lawyers” “The best tax firm I know” NEW YORK (June 24, 2024) — Kostelanetz LLP has been recognized by The Legal 500 as a leading firm for tax controversy in the United States, and Caroline Ciraolo has been named a leading partner by the
Low Risk Claims to Be Paid Beginning This Month The Internal Revenue Service (IRS) announced today that it would resume processing “low risk” Employee Retention Credit (ERC) claims, ending a moratorium on processing ERC claims that has been in place since last September. The announcement
Justices Avoid Addressing the Limits of Congress’s Authority to Tax Income Under the Sixteenth Amendment The U.S. Supreme Court in Charles G. Moore v. United States (No. 22-800), by a 7-2 vote, rejected a constitutional challenge to the Mandatory Repatriation Tax (“MRT”) imposed by IRC
