Overview
Bloomberg Tax quoted Steve Dixon in a January 3 article titled "Big Tech Fights Top Tax Law Issues to Watch in 2022." The article previews the big legal issues tax professionals are watching closely in the new year, including two high-profile cases concerning regulations that Treasury issued to implement the 2017 tax law.
Dixon said the two cases – Liberty Global, Inc. v. United States and FedEx Corp. v. United States – highlight taxpayer concerns about the validity of the IRS temporary regulations. And on Liberty Global, Dixon remarked: "I think that it’s going to be very interesting to see how the Department of Justice tries to defend those temporary regulations, because I think they have a lot of difficult choices to make in mounting that defense."
The full article can be read at Bloomberg Tax (subscription required).