Overview
On July 8, 2024, Bloomberg Tax quoted Larry Hill in an article titled “Move Over, Chevron: Corner Post Poses Extra Threat To Tax Rules.” The recent US Supreme Court decision in the Corner Post case has ushered in a new era of tax regulations by dramatically expanding the statute of limitations for procedural challenges. This ruling comes after the contentious Loper Bright Enterprises v. Raimondo decision, which eliminated the long-standing Chevron doctrine, previously offering agencies an advantage in court.
Steptoe tax partner Larry Hill spoke on the potential implications of these two landmark decisions, “These decisions are likely to open the floodgates to new cases that seek to relitigate decided issues.” He stressed the vulnerability of regulations in the current climate, stating, “No reg is safe from scrutiny.”
Hill further highlighted that these changes could significantly affect the way tax regulations are dealt with and challenged. He anticipates a substantial increase in the number of regulation challenges following these decisions, presenting a new landscape for tax practitioners to navigate.
In light of these changes, practitioners and agencies will need to adjust their strategies and prepare for the potential surge in legal challenges. This significant shift in the tax law landscape underscores the importance of staying informed and adaptable in the face of regulatory changes.
Read more at Bloomberg Tax (subscription may be required).
