Impact of Loper and Corner Post on Tax Regulations

Please join Holland & Knight's Tax Controversy and Litigation Practice for a virtual discussion regarding recent court decisions – including Loper Bright Enterprises v. Raimondo and Corner Post, Inc. v. Board of Governors of the Federal Reserve System – and their impacts on tax regulations.

Topics include:

• history and evolution of the Administrative Procedure Act (APA)
• levels of deference and application to tax cases
• how Loper, Corner Post and other cases will apply to tax regulation challenges
• how taxpayers and the IRS could approach potential challenges, and how to reconcile challenging tax regulations with the Tax Anti-Injunction Act
• the potential for an increased use of judicial doctrines
• effects on the regulation writing process, considering legislative history and drafting of stat language

We hope you can join us for this highly informative presentation.

Continuing Legal Education (CLE):

Please note: After the completion of the program, Holland & Knight will apply for CLE credit in the following jurisdictions based on attendee requests: California, Colorado, Florida, Georgia, Illinois, Iowa, Missouri, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Tennessee, Texas, Utah, Vermont, Virginia and Washington. Some programs may not be awarded CLE credits because of content or jurisdictional restrictions. Please be aware that the CLE approval process can be lengthy in some jurisdictions. Holland & Knight is an approved CLE provider in several jurisdictions, including California, Illinois, New York, Pennsylvania and Texas. For New York attorneys, this program's format qualifies for CLE for transitional (newly admitted) and experienced attorneys. General Certificates of Attendance will be provided upon request for states where applications are not submitted.