When regs lose their deference: Three cases rewrite the tax playbook

Welcome to Cross-Border Tax Talks, where we discuss the latest trends in international taxation, from US tax policy to the OECD's latest developments. I'm Doug McConey, PwC's International Tax Services Global Leader. PWC's Pillar Two engine, powered by Beacon, is a game changer for Pillar 2 compliance, provision, and modeling calculations.

Built on a graph system utilizing over 20 years of international tax technology. This cloud-based centralized rules engine is developed by a team of Pillar 2 tax experts from around the globe. PWC's Pillar 2 engine is currently available as a service and is also available to license. On this week's episode of Cross Border Tax Talks, we're back in PWC's Policy on Demand studio in Washington, D.C., where I'm excited to welcome Laura Williams back to the podcast.

Laura is an international tax partner in PWC's Washington National Tax Services office. Prior to joining PWC, Laura was a branch chief in the IRS office of Chief Counsel. Laura, welcome back to the podcast. Thank you, Doug. All right, so we're getting ready to kick off college football season. And you received, and that's American football for our non-U.S.

listeners. So you received your undergraduate and Master's of accounting at the University of Tennessee before attending law school. And the University of Tennessee is in the same football conference as my University of Missouri Tigers. So many of our non-U.S. colleagues have a hard time understanding our obsession with university athletics.

And it's very much a mystery to them. Can you describe your experience attending an SEC football game and why it was awesome when you were an undergrad there?

Yeah, well, it's hard to describe, right? Just because of the scale, the magnitude of the stadium. But I would say SEC is the best football in the country, by far, best conference.

By far.

University of Tennessee, the stadium holds over 100,000 people. Just the roar of the crowd, right, is overwhelming. So yeah, no, very excited for the season to kick off again. I don't get down to Knoxville as much as I would like to anymore. Um, but maybe, maybe I will start going back down.

I will note that our Big Ten fans and listeners, many of whom have been on this podcast, will definitely not agree that the SEC is the best uh conference in college football, particularly given the last couple of national champions. But I wholeheartedly agree. And what I'm excited about, University of Missouri this year is we added another, I think it was 20,000 seats.

So we had like 60,000, and now we've added 80 because we're kind of recent. I mean, it's been, I guess, 14 years since we've been in the SEC, but many of the stadiums there house over a hundred thousand people, which is just remarkable given the size and scale, and it is quite an experience. All right, so I'm still not gonna turn this into a sports podcast, Laura.

So we are gonna we are gonna talk about the validity of U.S. Treasury Department's regulations. But before we get into that, just to give some context, particularly for our non-U.S. listeners, can you explain the role that regulations play in our legislative process and remind folks just how does a bill become a law and then what the regulations do to those laws enacted by Congress?

Sure. I'd be happy to. Um, so means starting off, our Congress passes the laws, right? That's our legislative branch. They give us our statutory language. And then our executive branch is where our administrative agencies sit, right? So they are tasked with administering the laws, interpreting the laws, and enforcing the laws.

So when we talk about treasury regulations, we're talking about the tax regulations, interpreting Congress's tax code. And then, of course, judicial branch is our third branch of government. Those are our courts, right? They are tasked with interpreting Congress's statutory language, right, as it applies to taxpayers and, of course, the government.

And then there's a particular statute that was enacted by Congress that's it's section 7805A. Um, what does that specifically authorize Treasury to do?

It is a grant of regulatory authority, right, to Treasury and the IRS, right? They write regulations with the Treasury Department as the enforcement kind of bureau of Treasury. Um, and what 7805A says is that the Secretary shall provide all needful rules for the enforcement of the Internal Revenue Code.

And as we see as we start talking about some of these cases, there has been some healthy debate lately about what is the scope of 7805A, right? Treasury and the IRS would like for courts to take a very broad view of that authority, right? That allows them to write all of the regulations that they write.

Um, whereas, you know, some taxpayers may say, no, that's just for enforcement, right? That's about the administrative component of enforcing the tax law.

So I've been doing this for, I guess, almost 30 years at this point. And up until a couple years ago, I think the way I would generally characterize, particularly how the courts looked at regulations that were developed or enacted by the executive branch based on rules, as really giving broad deference to the Treasury Department, particularly in international tax matters, which are so highly complex, and the statutes tend to be relatively vague, and then we need much more detailed rules.

Um, but two years ago, and we covered a podcast on this very topic, was a Supreme Court case, Loper Bright, and the death of what was referred to as the Chevron defense. Remind listeners what Loper Bright said, because I think it provides really important context to these three cases that we're going to cover that have come out recently on international tax regulations.

It does, it does. Yeah. So Chevron was a 1980s Supreme Court case, and what that case told us was that when courts are evaluating the action of agencies, right, federal agencies through their regulatory process, there is deference given to the agency and the rules that they write when there's ambiguity in the statute.

So, right, Congress passes the law, there are unclear terms, or there are gaps in the statute. And so Chevron stood for the position that courts and judges were to defer to the agency when they wrote a rule to resolve that ambiguity, right, or fill that gap. And what Loper Bright said was no, right? They overturned Chevron, and so Chevron deference went away.

Um, and they pointed to the APA, which is our Administrative Procedures Act, which says that it is the role of the courts to do the interpretation of Congress's statutory language. And it is the role of the court to determine what is the best interpretation of that statute. Now there's a really important piece of LOPER that sometimes gets lost in the headline that Chevron Deference is gone, right?

And that is that the Supreme Court does acknowledge in LOPER that Congress will and does, right, delegate authority to write regulations or to fill in gaps or resolve ambiguity through the statutory process, right? So there's a there can be a delegation of authority from Congress for Treasury or any agency, right, to act.

And when the agency is acting within the bounds of that delegated authority, they are entitled to some deference. And so as we get into the cases, you'll see that the IRS and Treasury have really focused on arguing, hey, we were delegated the authority to write the regulations that we wrote.

And maybe talk a little bit about that, because you had some experience working at the IRS and that delegated authority, how does the IRS, and working with the Treasury, because both of those are within the executive branch, how does that process work at the government as far as regulations actually getting proposed, which we've talked a lot about proposed regs on the cross-border tax talks podcast, but all getting proposed and ultimately finalized?

Sure. So, I mean, Treasury and IRS work together, right? Treasury attorneys will sit with IRS chief counsel attorneys and they will draft regulations together. Every Treasury regulation that you will see, proposed or final, will have a section that discusses the authority that they exercised in proposing or finalizing that regulation.

And everyone that I've seen has referenced 7805A, right? The section that you brought up about the needful rules for the enforcement. But what you'll see throughout the Internal Revenue Code is specific delegations of authority. So some code sections will be more precise, right? They'll say the secretary shall provide or may provide rules that are necessary and appropriate to, you know, fill in the blank, right?

Prevent abuse or carry out the purposes of this section. And it's interesting because it doesn't seem clear the rhyme or reason why we get specific delegations of authority in some sections, but not others. But Treasury and IRS always are looking for a specific grant of authority from Congress and then acting, right, writing the regulations within the scope, trying to write the regulations within the scope of that boundary.

But as I mentioned before, they do take a pretty broad read of 7805A. And so some IRS or Treasury attorneys you talk to may say that gives us all the authority that we need. We don't really need specific grants of authority.

Okay. So we're going to dive into three recent cases, but all of them generally revolve around the Tax Cuts and Jobs Act from 2018. That was Trump's first big signature tax bill. Why has that been particularly a ripe topic for regulation validity, even outside the fact that we that we have the Supreme Court decision?

But I feel like this TCJA, there are a number of reasons why there are a bunch of issues from a validity perspective associated with some of those international tax regulations.

There are, yes. So it was massive change, especially in the international tax space. And so prior to TCJA, right, US multinationals operated in a deferral regime, right? So foreign subsidiaries, their earnings were not subject to any sort of current taxation at the US corporate level, right? Not until those earnings were repatriated back to the US would they be subject to tax.

And so the TCJA moved away from the deferral and into a territorial taxing system. In doing that, they implemented a new provision that we call guilty, right? And so it imposes tax on foreign subsidiaries of US corporations at a reduced rate of tax, right? So under the deferral regime, you had a very, very small amount of earnings in the subpart F, they're called subpart F that were subject to tax.

Now with the guilty regime, most of a foreign subsidiary's earnings are going to be taxed under the guilty regime. The parts that aren't, right? The earnings that are not subject to either the old subpart F regime or the guilty regime are eligible to be repatriated back to the U.S. as dividends, right?

Subject to a hundred percent dividends received deduction. And so that's the new TCJA regime. And in getting into that regime, there was a one-time transition tax.

Toll charge.

The toll charge, that's right.

We spent a lot of time talking about the toll charge on the cross-border tax talks podcast.

Yes, okay. So that was measured at the end of 2017 and all taxed in one, you know, one fail swoop at a very reduced corporate income tax rate, right? And so that moved us into the territorial regime. The problem, or the perceived problem, um, is that there was a mismatch in the effective dates of these provisions.

So you had the toll charge being measured at the end of 2017. You had the 100% DRD becoming effective for distributions at the very beginning of 2018 on January 1st. No matter when your tax year ended or began, January 1st was the effective date. And then the guilty regime was tied to the foreign subsidiary's tax year.

And so you had a period of time where earnings that were earned by a foreign corporation were not going to be subject to transition tax because that had already been measured, right? But they weren't yet subject to the guilty regime. And so it became known as the donut hole or the gap period. Um and Treasury became aware that taxpayers were doing things during this period that they found to be inappropriate.

Um, there's also a mismatch in the effective date of a gross-up that we're going to talk about when we talk about variant. Um, and so it's really the majority of these validity challenges are revolving around regulations where Treasury and IRS were trying to fix the mismatch of effective dates in the TCJA.

That's an amazing explanation. Um, maybe a couple points to add is the, you know, there were a number of CFCs of U.S. taxpayers at the time that had a different year tax year end for the CFC than the parent year end. And it kind of naturally created this mismatch for a lot of taxpayers where guilty wasn't applicable because they had an 1130 year end.

The reason that many of these CFCs had an 1130 year end is because this was back in the day when we were taxpayers were chasing the look through, right? And it was for taxpayers beginning on or after a particular date. So they changed their year end, which was elective, to November 30th. But then it created this mismatch for just a lot of taxpayers that had a calendar year end for the parent company and an 1130 year end for the CFCs.

And so it just a lot of taxpayers kind of ended up in this position, not necessarily for proactive planning, but just because that's was the facts at the time of that transition. And then obviously a major change that you articulated as far as just fundamentally how CFCs are taxed, and so they had to deal with this transition.

The other thing that I'm interested in you in commenting on was the TCJA, just like the one big beautiful bill act, was passed with very in a very quick amount of time relative to major international tax changes that we've seen over the course of my career, frankly, going back to the 80s. And there was also less legislative history as part of that process.

So less things for presumably both Treasury and the courts to really try to understand what the intent was of Congress as they made some of these rules.

That's right. That's right.

All right. So let's move into uh then the variant medical system. So this was originally a 2024 tax court case, and then in April of 2026, the tax court issued another opinion addressing the consequences of the original decision and this 245 cap A related to the DRD. So maybe tell us about the the variant medical systems case and what's at play here.

Yeah, so this is the first tax court case, major tax court case, that applied the Loper Bright standard, right? So we had Loperbright in June of 24. This came out in August of 24, and this was another mismatch in the effective dates. So essentially, Section 78 is a gross-up for foreign tax credit purposes.

It doesn't really matter the details of it, just know that the provision treats that gross-up amount as a dividend for all purposes of the code. And so when they passed this 100% DRD in 245 CAP A, they had to make sure that it was not treated as a dividend. They've been Congress not treated as a dividend for purposes of that deduction, because it would undo the effect of the gross up.

So they amended section 78 to say that, excluding, you know, not including for purposes of 245 CAPA, but they made the effective date again tied to the foreign corporation's tax year. And so for the toll charge, right, if you were a fiscal year taxpayer, it appeared that your gross-up could be eligible for 100% DRD.

And a lot of taxpayers took that position, including Varian. Um, Treasury and the IRS became aware of this glitch, right, when they saw the provisions of TCJA probably, and wrote a regulation in section 78 and essentially changed the effective date back, right? They said you can't take 245 cafe against the gross up.

And so Varian challenged the validity of that reg in tax court, and the tax court agreed with Varian. They said, look, you know, when Congress says something, we presume that they mean what they said, and the effective date is very clear. And the government made good efforts to try to argue why this wasn't really a dividend that 245 could be eligible, 245 Cafe would be eligible for.

So there was no explicit grant of authority in Section 78. There is a grant of authority in 245 CAFE, right, which says that the Secretary may provide or shall provide rules that are necessary and appropriate to carry out the provisions. And so Treasury and IRS rely on the broad authority in 7805A and also the narrow authority in 245 CAFE G, but neither are sufficient to overcome, right, the plain language and the clear effective dates of Section 78.

Yeah, really important case. And maybe just to add one thing to Section 78, because this is always confusing for people that are trying to understand our system. The way I think about Section 78 is that because we have a foreign tax credit system and CFCs get effectively a deduction for the foreign taxes that they're paying when they make a distribution, that Section 78 gross up just effectively prevents taxpayers from getting both a deduction for the foreign taxes and being able to get a credit for it.

So you have to add those credits back to the dividend, which from a policy perspective, one could argue why that should not be subject to the Section 245 CAP A DRD deduction. But I think the lessons is it it matters what Congress wrote. It does.

That's right. And Treasury and the IRS raise these arguments, right, about policy and congressional intent. And it's very important. The tax court says look, general policy concerns, right, and congressional intent cannot override clear statutory language, right? They're not going to even get to the legislative history or lack thereof, right?

Or the intent of Congress in promulgating these rules if the language is clear on its face.

All right, so let's turn to key site technologies, which is the most recent case that was decided in July 2nd, 2026, where the Court of Federal Claims invalidated a particular regulation. Tell us about that.

Yes, so these are the extraordinary disposition transactions that occurred during that gap period we were talking about, right? When there were CFCs that were not subject to the guilty regime yet, but transition toll charge had already occurred. And so Treasury and IRS became aware that taxpayers were engaging in taxable transactions with CFCs, right?

And related parties with CFCs in an attempt to, or successfully attempting to, um, step up the basis of assets and generate earnings and profits during this period when they wouldn't be subject to tax.

And where that future amortization would then reduce guilty going forward. So effectively a tax-free step up, and then you get deductions for guilty in the future.

Exactly. Imagine you can take all of your valuable assets offshore, like IP, and sell it from one CFC to another, assuming you can do it in a way that doesn't trigger a bunch of foreign tax, right? From a US perspective, now I have fair market value basis, I can amortize it against my tested income going forward.

And so what these regulations at issue in Key Site did was they said, no, that amortization and that depreciation of the basis that you created during that gap period is not going to be allocated against your guilty. It's going to be allocated against the residual basket of income, that income that would have allowed you to, you know, make tax-free dividends pursuant to the DRD, right?

So allocated the deductions away from tested income, basically neutralizing the effect of the sale for taxpayers. And so the taxpayer challenged the validity. This is in the Court of Federal Claims, and that's important because it does have limited precedential value, right? But the tax court, the taxpayer argued that the regulations were contradictory to section 951 CAP A, and that Treasury and the IRS had no authority to issue those regulations.

The government only had section 7805A here because there for some reason is no explicit grant of authority in 951 CAPA, which is our guilty provisions, right? There's a very narrow delegation of authority with respect to tangible assets. But here, no express grant of authority, and that was really important to the judge in this case.

He said 7805A alone is not sufficient to write these regulations. You would need a more specific grant of authority in order to provide these rules. He said taking that broad interpretation of 7805A would essentially give Treasury and IRS the ability to rewrite all of the internal. Revenue code, right?

And then override it based on their, you know, interpretation of what is needful or what the best policies are. And so refused to go that far and said you would need a more specific grant of authority.

So Varian was a tax court case, and you had mentioned the key site I mentioned is the Court of Federal Claims. This is also a number that can be very confusing, frankly, for U.S. practitioners and non-U.S. practitioners. So who can rely on the federal on this case as precedence for the Court of Federal Claims versus the tax court?

And then we also have our appellate courts. Can you spend a couple minutes?

Yeah, it's it's very limited for purposes of the Court of Federal Claims. I think it's getting a lot of attention, though, because the analysis is broad-reaching, right? You have a court and a judge who's willing to narrow the interpretation or the reach of 7805A. But essentially, there is no precedential value for the Key Site case.

The tax court case is precedential, right? And as we'll get into it, you have all of the tax court judges, both invariant and Siemens, right, agreeing to the analysis. And so you would expect to see very broad reach of their analysis there in future tax court cases. Now, taxpayer and government can appeal like these decisions, in which case they'll go to the federal district that the taxpayer is located in.

And then from there, right, they can be appealed again and eventually could maybe make their way to the Supreme Court if you end up with a sufficient circuit split and interest by the Supreme Court.

There's nothing more exciting than an international tax case that ends up at the Supreme Court. We don't get those very often. We'll see if we're headed there though.

That's right. I mean, TCJA did give us the Moore case, so it wouldn't be the first time.

We spent plenty of time covering that case. So this seems like, and we're going to talk about the Siemens case, that you know, if there's enough of these different cases, then maybe those could kind of be consolidated and brought up through the Supreme Court, but I don't want to get ahead of ourselves.

So let's talk about the Siemens Medical Solutions versus Commissioner, which was published July 15th, 2026.

Can I say one more thing on Peace Site though? Yeah, yeah. Because it the judge goes on to do a loper analysis of what does it mean to be properly allocable? And I just wanted to go back to it because it's important, right? Once he concludes that the Treasury and IRS weren't delegated the authority to write those regulations, he steps into the LOPER standard and says, I, as the judge, right, am going to determine what's the best interpretation of the words properly allocable.

And he was more persuaded by the taxpayer's argument that look, a amortization or depreciation deduction related to this asset that generates guilty income, right, it's factually connected and it so it should be allocable against that type of income. And he said, yes, I agree.

And that feels pretty straightforward. Um and frankly, if it wasn't the case, then the IRS wouldn't have needed to issue that regulation anyway, otherwise.

Agreed.

All right, so let's move on to Siemens then.

unknown Yes.

So Siemens also involved extraordinary dispositions, but these are different regulations. So these regulations were issued under Section 245 CAPA, and they dealt with all the earnings and profits that were generated in these gap period transactions, right? So CFC sells its asset, it recognizes a lot of gain, that gives it a lot of EMP, that can now be distributed up to the US and qualify for the dividends received deduction.

There's other ways to use EMP to shelter gain, but putting that aside, the regulation at issue was 245 KFA-5, and what it said was that the dividends received deduction that would otherwise be allowable to that taxpayer is denied 50%. So essentially getting the taxpayer back into the tax position as if that sale had been subject to the guilty regime.

And so Siemens argued that the regulation was contrary to the plain language of 245 CAFA, right? That they were clearly entitled to the deduction. It came from a foreign corporation, they met all the holding period requirements. And so this was an inappropriate and invalid regulation. And here the Treasury and IRS had a more specific grant of authority than they did in Key Site, right?

So they had 245 CAPA G, which says secretary can provide all rules that are necessary and appropriate to carry out the provisions. And the government argued that in determining what's necessary and appropriate, you have to look to the context, right? So they wanted to look at the whole TCJA regime and they said look at the policy behind it.

That's right, yeah. So look at the context, right? The interaction of transition tax guilty 245 cap A. And when you look at all of those together, Congress would not have intended, right, for these types of earnings to qualify for the DRD and escape taxation in the guilty regime. And so the tax court, again, all judges, right, except for one who was recused because she was at the IRS at the time that these regs were promulgated, agreed with the taxpayer.

And they said the statute is clear. It's you're trying to change the effective dates that Congress clearly provided, right? And asking us to speculate about whether they intended that result. Um, but where the language is clear, we don't need to get into any of the other like inquiries into context. They said we agree, like context matters, but Treasury and IRS were not trying to construe language here.

What they're really doing is trying to fix the mismatch and effective dates, and we don't, we're not going to go there.

All right. So I mean, these are all fascinating cases, all issues that we've obviously thought a lot about. Um, but now I want to turn maybe to some more some of the practical implications for taxpayers and for listeners. So what are the practical implications for those that have relied on these regulations for, I mean, these are years now, um, and then suddenly these are invalid.

Yeah, I mean, we're talking to companies about protective refund claims, right? If they did an extraordinary disposition and have been following the regulations, you know, there's the possibility potential to go back and amend returns and file those protective refund claims. Um, we're also talking about, you know, changing positions on future returns or changing your financial statement positions if you have been, you know, treating it as a position that you've reserved against, for example.

Um, this gives taxpayers a lot more certainty. Now, it's worth noting that a lot of these cases, if not all of them, started when we were still in the pre-Loper bright era. Right. Right? So a lot of people.

When they were originally filed and when this was brought up.

Yeah, so I mean, taxpayers were thinking that these regs were invalid and they were gonna succeed even if the government got Chevron deference, right? And so Loper Bright made it even more likely, right, for these results to happen. So um, I think revisiting, you know, historical positions, thinking about your prospective positions, um, that's mostly what we're we're talking to to companies about.

But I think it's worth noting that the government has said um in in the past that they intend to defend their regulations, right? And so they have the ability to appeal this decision, the tax court decision. Um, and so we it may be a while before we have final resolution on the validity uh of these rights.

Yeah, we haven't heard anything, or has has there been any public pronouncements about whether they plan to appeal on any of these?

Not that I have heard. I mean, we're several years out from the variant decision now. Of course, they had a second um, you know, issue that just made its way through, you know, and we've received the opinion. Um, so they still have time, right, to appeal any of these, but um no, I haven't heard anything.

So is can Treasury maybe fix this problem through issuing new regulations? I mean, is there are there any uh vehicles that the Treasury may have other than just appealing these decisions?

It's hard to imagine that they would do anything through regulations. All of the cases we talked about today involve a historical problem, right? It was isolated to 2018, it's way in the past now. Um I think the bigger risk or concern might be the use of alternative arguments, right, um, by Treasury or by the IRS in controversy.

Um they'd say, okay, fine, putting aside the regulation, we still think that the benefit is denied under another principle or another rule.

So let's go there. That's a perfect teed me up perfectly, Laura. So um, you know, one of the things that we've seen, there's been the codification of our economic substance doctrine, 7701-0, and there's been a surge of economic substance arguments that the IRS has been racing against taxpayers, and we're seeing some of those come through the courts, specifically the Liberty Global decision, which we talked about on this podcast several months ago.

Um, how does this surge of economic substance argument raised by the IRS potentially relate to this invalidity argument?

Well, I think you're exactly right to bring up the Liberty Global case for this question, right? Because there you had a taxpayer who challenged the validity of a regulation and succeeded. It was on procedural grounds, but succeeded in invalidating the reg in the 10th circuit. Um and then what we saw was the government filed a counterclaim months later asserting economic substance, right?

So they said, we're not giving you the refund. Put the reg aside, right? We think your transaction lacks economic substance. And for that reason, right, we're not going to provide the refund. And so I think what we're seeing is a flurry of cases in controversy where the government is raising, of course, their regulation, but then alternative arguments, including these judicial doctrines like economic substance.

And you're right, there's been an increase in the assertion of economic substance cases. And so when we talk to companies about their positions, are they going to challenge the validity of a regulation? Are they going to take a position contrary to a regulation, even one that's subject to these in these cases where courts have found them to be invalid, you have to think about the government's next move, right?

And could economic substance be raised in these cases? They weren't here, right? We didn't see it in Ciemens or in Keysight, but could the IRS say, we're going to deny the benefit of the DRD or the amortization on the basis that your transaction that got you into these rules lacked economic substance?

Yeah, so I think for for taxpayers that that did a transaction of that type, um, you know, during the the donut hole period, the so-called donut hole period. I don't know who actually coined that that term. I feel like there are better terms. But um, you know, very important for those taxpayers to understand what was the business purpose and economic substance for those transactions.

Is that sustainable if you are going to try to litigate or you know take that position with the IRS? Because I do think that's a logical conclusion that we could see the IRS continuing to raise this, knowing this flurry of recent cases that went against them on the invalidity piece.

That's right. And we're getting more guidance on what is, you know, what is the standard for economic substance. And so taxpayers should go through that exercise of is it relevant to my transaction? What was my business purpose? Is it substantial enough? Things like that.

All right. Well, Laura, thank you very much for joining this week's edition of the Crossborder Tax Talks Podcast.

Thank you.

So thanks for tuning in to this week's episode of Crossborder Tax Talks. Thank you, Laura Williams, international tax partner in PWC's Washington National Tax Services Office. I'm Doug McConey, PWC's International Tax Services Global Leader. Stay tuned for another exciting edition of the Crossborder Tax Talks Podcast.

This podcast is brought to you by PWC, all rights reserved. PWC refers to the U.S. member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PWC network. Each member firm is a separate legal entity. Please see www.pwc.com slash structure for further details. This podcast is for general information purposes only and should not be used as a substitute for consultation with professional advisors.

When regs lose their deference: Three cases rewrite the tax playbook

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