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The Tax Cuts and Jobs Act (TCJA) was hastily enacted and ushered in a sea change to how the U.S. imposes tax on international operations; it was inevitable that litigation...
The Treasury Department is using arguments based on standing – Constitutional Article III standing and statutory standing – to persuade the D.C. Circuit that it should not decide the merits...
Key Takeaways - ..The pending case, Silver v. Internal Revenue Service, will provide insight, when decided, of the view of the Court of Appeals for the District of...
The pending case, Silver v. Internal Revenue Service, will provide insight of the view of the Court of Appeals for the District of Columbia Circuit on scope of judicial review of administrative regulations that apply to small business.