Unanswered questions after Mayo

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

Cookies Settings

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

FeatureITR MagazineOctober 2011
more across site & shared bottom lb ros

More from across our site

Direct Tax
r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.
Navigating the R&D landscape in 2026: implications for tax professionals
Businesses that adopt a proactive strategy and work closely with their advisers will be in the greatest position to transform HMRC’s relief scheme into real support for growth
Robert Whiteside, CEO of EmpowerRD , January 20 2026
Direct Tax
Australian Company Tax Return concept
Australian taxpayers blocked from leaving country over unpaid debts
The ATO and other authorities have been clamping down on companies that have failed to pay their tax
Tom Ravlic, January 20 2026
Direct Tax
Washington DC Capitol view on cloudy sky background
A big, beautiful analysis of the One Big Beautiful Bill
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Barry Herzog, January 16 2026
Direct Tax
Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC
PwC Middle East announces leadership transition
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
Sam Sholli, January 16 2026
Direct Tax
Treasury has released final and proposed BEAT regulations
A taxing week: Solution for tax agent regulator not a solution for all
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Tom Ravlic, January 16 2026
Direct Tax
Pillar two is revising global tax competition with a 15% minimum tax rate
This week in tax: Businesses should prepare for pillar two disputes, firm warns
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran
Sam Sholli, January 16 2026
Transfer Pricing
EY
EY hires four senior PwC tax partners in Australia
Among those joining EY is PwC’s former international tax and transfer pricing head
Sam Sholli, January 15 2026
Direct Tax
Grant Thornton.jpg
Grant Thornton UK adds eight tax partners
The UK firm made the appointments as it seeks to recruit 160 new partners over the next two years
Sam Sholli, January 14 2026
Direct Tax
Irvine, CA, USA - May 6, 2022: Exterior view of Baker Tilly's office in Irvine, California. Baker Tilly US, LLP is a public accounting and consulting firm headquartered in Chicago, Illinois.
Baker Tilly International records 31% tax service line growth
The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period
Sam Sholli, January 14 2026
Direct Tax
Base_of_two_pillars_at_Viborg_Katedralskole_320x215
‘Sigh of relief’ for multinationals after pillar two side-by-side agreement
The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR
Sam Sholli, January 13 2026
Gift this article