Caroline Rule was quoted in a recent Bloomberg Tax article about the broad implications of a corporate tax loophole that the U.S. Tax Court upheld in its August 2024 decision in Varian Medical Systems Inc. v. Commissioner, 163 T.C. No. 4. The article, titled “Cisco, Booking Get Big Tax Benefits
By Abigail Burke and Malena Solin The CPA Journal November 2024 In a recent article for The CPA Journal, Abigail Burke and Malena Solin address the U.S. Supreme Court’s landmark 2023-2024 term, which included two cases with significant implications for future litigation over executive branch agency regulations and actions. In
Kostelanetz attorneys Andrew Weiner and Abigail Burke were quoted in Thomson Reuters tax and accounting publication, Checkpoint, regarding the case of John Paul Salvador v. United States (No. 24-108). Previously, Andrew and Abigail co-authored an amicus brief on behalf of the American College of Tax Counsel (ACTC) supporting Salvador’s petition
Kostelanetz counsel Gray Proctor presented a virtual CLE session through the Florida Bar, “Tax Penalties after the Revolution of Summer ’24”. The session covered how IRS penalties in future tax controversy and criminal tax fraud cases may be affected by the outcome of SEC v. Jarkesy, a Supreme Court case
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. NYC Department of Homeless Services (DHS),
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 Reserve System, the Supreme Court
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 Enterprises v. Raimondo and in
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 965. The MRT is a
Kostelanetz LLP has filed an amicus brief on behalf of the Center for Taxpayer Rights in support of petitioner Philip G. Groves in Groves v. Commissioner, T.C. No. 9974-22L, a case involving the IRS’s assessment of tax penalties. The petitioner is challenging penalty liability on the ground that the IRS
Kostelanetz LLP has filed an amicus brief on behalf of the American College of Tax Counsel (ACTC) in Diane Zilka v. Tax Review Board City of Philadelphia (No.23-914), a case involving Philadelphia’s wage tax where the petitioner is seeking a writ of certiorari from the U.S. Supreme Court. Philadelphia’s wage
