How the Home Concrete ruling has hampered the IRS

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

How the Home Concrete ruling has hampered the IRS

hill-puff.jpg

US taxpayers breathed a collective sigh of relief in April when the Supreme Court delivered its verdict in Home Concrete which stated that the Internal Revenue Service (IRS) was not permitted to use an extended six-year statute of limitations period to investigate overstatements of basis. But there was a broader issue at stake in the case – the IRS’s ability to issue regulations and apply them retroactively. Joe Dalton explores the wider implications of Home Concrete and why US taxpayers will be hopeful the ruling will diminish the IRS’s arsenal in avoidance cases.

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
more across site & shared bottom lb ros

More from across our site

HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Jeff Soar lifts the lid on WTS UK’s ambitious recruitment plans, the firm's positioning against the big four, and why tax is the perfect profession for AI
The move reinforces Milan’s role as a key European hub for international business, the firm said
Australia’s government has also announced that it will implement the pillar two side-by-side agreement
Sara Morgan is due to join Joseph Hage Aaronson & Bremen as a partner in London, ITR understands
The newly combined tax team has already worked on thousands of joint client matters, leaders from McDermott Will & Schulte tell ITR
As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate
New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities
Gift this article