Modal title

In this article, Tom Greenaway of KPMG's Tax Dispute Resolution Network surveys the many Administrative Procedure Act challenges to Treasury regulations. This article was originally published in the January 8, 2018 issue of Tax Notes.

The IRS and the APA: Denial Is Not a Strategy

Related services

Service

Tax services

Our broad range of tax planning and compliance services can help you manage tax risks and opportunities.

Helping tax leaders embrace disruption, seize new opportunities and drive greater value. It’s tax re-imagined. Now and for the future.

Request for Proposal

Find out what KPMG can do for your business.

Submit RFP

Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

Legal
Privacy
Terms of use
Media

©2020 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.

The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

U.S. Tax Reform

Opportunity Zones

KPMG Spark

Tax Reimagined

Sec. 163(j): Passthroughs – Business Interest Expense Deduction Limitations

TWIST - August 10, 2020

2019 Global Financial Reporting and Valuation Conference

The IRS and the APA

Tom Greenaway

Related content

Related services

Tax services