Blog Posts September 16, 2019

Treasury’s Section 482 Regulation Losses

Do what Treasury said, not what it says it meant. Earlier this month, our Federal Tax Group explains why the circuit court affirmed one Tax Court decision and reversed another in the name of consistency – and why it means regulation preambles are more important than ever. Affirming in Amazon, reversing in Altera Holding the IRS to literal terms of the regulation Similarity to the Supreme Court ruling on the census citizenship question Read the full advisory here. [...]Read more

The post Treasury’s Section 482 Regulation Losses appeared first on Alston & Bird Tax Blog.

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