Unanswered questions after Mayo

September 30 2011

The US Supreme Court’s decision in Mayo earlier this year caught the attention of tax professionals. George Hani and Alan Horowitz of Miller & Chevalier, Washington, DC, argue that the full impact of the case will depend on the outcome of a new case addressing whether deference is owed to a more aggressive effort by the IRS to issue regulations with retroactive effect.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & bottom lb ros

More from across our site

Transfer Pricing

India Budget 2025: ‘Block TP Assessment’ to ease compliance burdens

The proposed Block TP Assessment could provide taxpayers with long-term arm’s-length price certainty and reduce admin headaches, Sanjay Sanghvi of Khaitan & Co writes

Sanjay Sanghvi, February 05 2025

Indirect Tax

Marmaris, Turkey – March 27, 2022. M/Y Eclipse superyacht owned by Russian oligarch Roman Abramovich, in Netsel Marina port of Marmaris, Turkey. Built by Blohm+Voss of Hamburg

This month in indirect tax: Abramovich hit with VAT evasion allegations

India’s budget changes goods and services tax rules; UK private school VAT challenge fast-tracked

Ralph Cunningham, February 05 2025

Direct Tax

US withdraws from UN global tax treaty negotiations

It is understood that the US has vowed to oppose any outcome from talks taking place at the UN

Sam Sholli, February 04 2025

Direct Tax

RSM records double-digit tax revenue boost as turnover hits $10bn

It’s the second year in a row that RSM’s tax business has posted fee income growth above 10%

Tom Baker, February 04 2025

Direct Tax

India: Reassuring guidance on tax treaty entitlement for cross-border transactions

Recent guidance from the Indian tax authorities should provide confidence for investors, says Sanjay Sanghvi of Khaitan & Co

Sanjay Sanghvi, February 03 2025

Direct Tax

‘Considerable uncertainty’ over Trump’s pillar two memo: KPMG policy head

Grant Wardell-Johnson also suggests there could be solutions to the friction between the US and the OECD when it comes to pillar two

Sam Sholli, February 03 2025

Direct Tax

Trump prepares to impose 25% tariffs on Canada and Mexico

The president had so far avoided announcing tariffs on the US’s neighbours despite previous threats

Sam Sholli, January 31 2025

Direct Tax

This week in tax: A&M continues ‘big four’ recruitment drive in Europe

The firm brought in three managing directors from EY and Deloitte in Europe; in other news, KPMG’s bid to practise law in US was delayed

Sam Sholli, January 31 2025

Indirect Tax

‘No benefits for taxpayers’: Advisers debate External Revenue Service

One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff

Sam Sholli, January 30 2025

Transfer Pricing

2025 growth business. wooden block with 2024 change to 2025, Set up objective target business cost and budget planning for new year concept

Transfer pricing trends for 2025: looking back to look ahead

From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025

Martin Bonner, January 30 2025