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Chevron Deference: History and Current Impact on United States Taxation

CHEVRON DEFERENCE: HISTORY AND CURRENT IMPACT ON UNITED STATES TAXATION

This is a special replay of a previously recorded webinar.
Cost Free
Presentation Length 1.0 hour

Recorded DateNovember 8, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaBusiness Law
Course LevelBasic
Course Description

In late June 2024, the Supreme Court heard the case Loper Bright Enterprises v. Raimondo which largely overturned the administrative law doctrine known as Chevron deference. Chevron deference gave federal agencies the ability to make interpretations of actions implied by a law as informed by the agency's subject-area expertise. This decision has wide-ranging effects, the most sizable of which will be felt in the tax world.

This course will cover the historical importance of Chevron deference and the Supreme Court's decision in "Raimondo" in detail, then address what this means from a tax perspective, including opportunities that may arise as a result of this ruling.

Learning Objectives:


  • Identify the historical significance of Chevron deference

  • Evaluate the Supreme Court decision in Loper Bright Enterprises v. Raimondo which overturned Chevron deference

  • Recognize how this can affect the Internal Revenue Service and individual tax practitioners

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Patrick McCormick is an attorney with over a dozen years of experience, focusing his practice specifically on international taxation. Mr. McCormick represents both business and individual clients on all aspects of United States international tax rules, both from an income tax and estate/gift tax perspective. Having previously served as a partner at a large law firm, a midsized accounting firm, and a boutique tax law firm, Patrick’s client exposures have covered every conceivable area of American-side international tax matters. Patrick has also represented every type of taxpayer – from multibillion-dollar business enterprises and ultra-high net worth individuals to startups and individuals with complex questions but limited budgets.

Mr. McCormick has worked with clients located in over 90 countries on American tax considerations of multinational activities, cultivating specialized knowledge in every area of United States international tax rules. His explicit practice focus has facilitated an unparalleled expertise in the field; Patrick is trusted by clients and advisors around the world to obtain optimal results on international tax matters.

Mr. McCormick is a primary and prolific authority on tax matters. He has spoken on all aspects of international tax to hundreds of thousands of attendees around the globe, functioning as the primary international tax resource for national organizations including CPAacademy.org, Strafford, Lawline, and Leimberg Information Services. Patrick has presented for the American Bar Association, the American Immigration Law Association, and state and local bar associations around the United States. He is a regular contributor to America’s premier tax law publications, including Tax Notes, Journal of Taxation, Tax Notes International, Law360, and Practical Tax Lawyer.

Mr. McCormick published his first treatise on international tax matters, Allocation and Apportionment Rules Under Secs. 861-865, for Thomson Reuters’ Catalyst platform, in October 2021. In late 2021, he also released a 15-hour digital course entirely dedicated to nonresident taxation, United States Tax Considerations for Nonresident Taxpayers. Mr. McCormick has been named a Super Lawyers Rising Star from 2016-2022.
 

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