Unanswered questions after Mayo

September 30 2011

The US Supreme Court’s decision in Mayo earlier this year caught the attention of tax professionals. George Hani and Alan Horowitz of Miller & Chevalier, Washington, DC, argue that the full impact of the case will depend on the outcome of a new case addressing whether deference is owed to a more aggressive effort by the IRS to issue regulations with retroactive effect.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

AI in tax: what’s the direction of travel?

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems

Russell Gammon, July 01 2025

Direct Tax

Lewin Higgins-Green -- FTI Consulting.jpg

Five minutes with…Lewin Higgins-Green, FTI Consulting

FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool

July 01 2025

Direct Tax

Canada to scrap DST in bid to resume US trade negotiations

Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025

Sam Sholli, June 30 2025

Direct Tax

PwC Australia’s government contract ban should be extended, senators say

The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR

Tom Ravlic, June 30 2025

Transfer Pricing

DSTs as digital infrastructure: the tax challenges of emerging markets

Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria

Neil Kelley, June 27 2025

Direct Tax

Pillar two taxes won’t apply to US companies: US Treasury secretary

A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed

Sam Sholli, June 27 2025

Direct Tax

This week in tax: PwC Australia’s tax function generates A$475m amid tumbling 2024 profits

The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches

Sam Sholli, June 27 2025

Transfer Pricing

Nigeria and India unite in bid to ‘tackle abusive TP’

Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood

Sam Sholli, June 26 2025

Transfer Pricing

Five minutes with…Farhan Azeem, PKF Littlejohn

The UK accountancy firm’s transfer pricing lead tells ITR about his expat lifestyle, taking risks, and what makes tax cool

June 26 2025

Direct Tax

EY client fails in ‘£16m’ UK Supreme Court tax claim

Dolphin Drilling intends to discuss the final liability amount and manner of settlement with HM Revenue and Customs

Sam Sholli, June 25 2025