Alston & Bird Tax Blog

The Treasury’s New Guidance Policy

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What guidance has the “force and effect of law”? Our Federal Tax Group dives into an appeal of a court case involving Notice 2016-66, the Anti-Injunction Act, and a new Treasury policy statement that could upset the department’s applecart.

  • A new transaction of interest: micro-captive transactions
  • Policy Statement on the Tax Regulatory Process
  • Eviscerating the premise of an argument

Read the full advisory here.

About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

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