How To Challenge Tax Regs On Administrative Law Grounds

Overview


In Depth


Roger Jones, Andrew Roberson and Lowell Yoder wrote this bylined article analyzing Altera Corp. et al. v. Commissioner, a US Tax Court decision that invalidated regulations under the IRS arm’s-length standard. “The opinion is a victory for taxpayers,” the authors wrote, adding that “its limits on the IRS’s rulemaking authority could be felt more broadly in the transfer pricing area, as taxpayers may challenge other current (and possibly future) regulation provisions that might not be adequately grounded in the arm’s-length standard.” Read the full article (subscription required).