Loper Bright's Impact on Foreign Taxation: Challenges to Existing IRS and Treasury Regulations
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This webinar will review the potential impact of the Supreme Court's decision in Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244, 2273 (2024) on global taxpayers. Our panel of international tax advisers will examine the decision and the history of courts' deference to agency interpretations and suggest appropriate strategies for taxpayers as they consider how the new standard may impact existing rules and regulations. They will point out regulations that are most likely to be challenged under the new standard.
Outline
- Introduction
- Background
- The Loper Bright decision
- Implications
- IRS: impact on IRS and Treasury regulations
- Taxpayers: strategies and challenges
- Future drafting of law
- Examples of regulations that might be challenged
Benefits
The webinar will cover these and other critical issues:
- Actions international taxpayers should consider after the SCOTUS Loper Bright decision
- Examples of regulations that might be challenged
- Possible changes in IRS settlement approaches
- Effect on litigation and refund claims
Faculty
Surbhi Bordia
Partner
Armanino
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact... | Read More
Ms. Bordia has over 10 years of public accounting experience. She addresses complex tax issues that impact international companies’ operations and puts tax efficient structures in place for her clients. Ms. Bordia’s hands-on experience in international tax, IP migration planning and legal entity rationalizations make her an expert consultant and key team player for clients in mergers and acquisitions. Ms. Bordia’s focus areas include GILTI, BEAT, FDII, anti-hybrid rules, foreign tax credits, subpart F, withholding tax, investments in U.S. property, FX gains and losses, treaty-related issues, outbound transfers and permanent establishment and profit attribution rules.
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Kodj Gbegnon
Principal
PwC
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San... | Read More
Mr. Gbegnon is a partner in the International Tax Services practice at PwC’s Silicon Valley office (San Jose). His practice focuses on tax planning for cross-border M&A and restructurings, IP integration, taxation of online / digital transactions and tax attribute planning (including foreign tax credits). Mr. Gbegnon is a member of the California Bar Association.
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Nick Zemil
Director
PwC
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on... | Read More
Mr. Zemil focuses his practice on assisting taxpayers with large-scale international tax issues, with an emphasis on outbound transactions. Prior to joining PwC's Washington National Tax Services group, he was an associate at an international law firm where his practice focused on cross-border tax controversy issues ranging from the audit stage through litigation. While attending the University of Virginia School of Law, Mr. Zemil was on the editorial board of and was a contributor to the Virginia Tax Review.
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