Lisandra Ortiz will present, as a part of a panel, "More than Moore: Regulatory Challenges after the Supreme Court's Decisions in Loper Bright and Corner Post" to the USA Branch of the International Fiscal Association (IFA USA) on July 24, 2024. The panel will discuss two recent Supreme Court decisions that have brought a seismic shift to U.S. federal tax law. The Supreme Court’s opinion in Loper Bright Enterprises v. Raimondo affects the way courts will resolve challenges to Treasury Regulations. We now expect challenges to a large number of Treasury Regulations, and courts, rather than the Treasury Department, may take on the central role in interpreting the Internal Revenue Code. The Supreme Court’s opinion in Corner Post Inc. v. Federal Reserve defines the start of the statute of limitations for challenging regulations under the Administrative Procedure Act. Together, these two nominally non-tax decisions change how taxpayers will challenge tax regulations. Topics include: 

• Implications of the Supreme Court’s decisions in Loper Bright Enterprises v. Raimondo and Corner Post Inc. v. Federal Reserve
• The new legal framework for challenging Treasury Regulations.
• The statute of limitations for a taxpayer to make facial challenges Treasury Regulations under the Administrative Procedure Act