• Skip to primary navigation
  • Skip to main content
  • Skip to primary sidebar
  • Skip to secondary sidebar

Alston & Bird Tax Blog

  • Home
  • Services
  • Contacts

The Treasury’s New Guidance Policy

April 2, 2019 By Jasper L. (Jack) Cummings, Jr.

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.

Filed Under: Federal Tax Advisory Tagged With: Anti-Injunction Act, IRS, micro-captive transactions, Treasury

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.

[Read Bio]

Primary Sidebar

As a service of Alston & Bird’s Tax groups, this blog focuses on current issues and events in international, federal, state and local tax and wealth planning of interest to business.

Subscribe

Receive email notifications when new posts are added.

Check your inbox or spam folder to confirm your subscription.

Tags

401(k) ACA Affordable Care Act audit BEAT CARES Act CFC Corporate Tax Planning covid-19 Delaware ERISA Escheat FATCA FDII Gift cards GILTI international tax IRA IRAs IRS Kelmar New York nexus OECD qualified plans Quill RUUPA SCOTUS Section 351 Section 355 Section 367 Section 385 section 482 section 965 State legislation Subpart F Supreme Court Tax Court Tax Cuts and Jobs Act tax reform TCJA Treasury Unclaimed property UP Wayfair

Secondary Sidebar

Categories

Recent Posts

  • Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences
  • Top Unclaimed Property Regulatory and Enforcement Challenges in 2021
  • If at First You Don’t Succeed, Try, Try Again to Enact the Nation’s First Digital Advertising Services Tax
  • Digital Services Taxes and Nexus for Foreign Tax Credit Purposes
  • FAQs on Unclaimed Property Aspects of Retirement Assets

Archives

Copyright © 2021 · Alston & Bird · All Rights Reserved. Privacy.