To Defer Or Not To Defer: Kisor's Impact On Tax Controversies

Law360 (September 13, 2019, 4:50 PM EDT) -- In the wake of the substantial change to the Internal Revenue Code as part of tax reform, the U.S. Department of the Treasury and the Internal Revenue Service have been issuing regulations and guidance relating to the new paradigm.

As the new rules get interpreted by the IRS, we expect that courts will wrestle with questions regarding whether they should defer to the agency's interpretations. But, some of the new tax statutes were not a model of clarity, and the guidance being issued by the IRS may be viewed as overreaching.

At the end of its last term, the U.S. Supreme...

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