Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations

By David Shakow The Supreme Court’s decision in Mayo Foundation for Medical Education and Research v. United States means that tax practitioners must be more sensitive to administrative law and judicial deference to administrative rules.  This includes gaining some familiarity with the Administrative Procedure Act (APA) and the major cases that deal with judicial deference … More Who’s Afraid of the APA?: The Application Of Administrative Law To Tax Regulations

When Is Debt No Longer Debt? Treasury Proposes To Ease Debt-Modification Regulations

By Jonathan Prokup Times are tough, and many troubled companies are facing the need to modify debts that were issued when times were better (and the companies were financially much stronger).  For companies that wish to modify their debts, and for investors that hold those debts, federal tax law imposes an unfortunate limitation.  An outstanding … More When Is Debt No Longer Debt? Treasury Proposes To Ease Debt-Modification Regulations