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Tax consulting firm permitted to challenge final micro-captive reporting regulations

By Samuel F. Hamer on December 2, 2025

Ryan, LLC v. Internal Revenue Service[1] is the latest example of success in overcoming procedural hurdles to challenge the validity of a US Department of the Treasury (Treasury) regulation. In a recent opinion, the US District Court for the Northern District of Texas held that: Ryan has standing to challenge the validity of the Treasury’s […]

  • Posted in:
    Tax
  • Blog:
    Tax Controversy 360
  • Organization:
    McDermott Will & Emery
  • Article: View Original Source

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