Has the Supreme Court Made Treasury Regulations Easier to Challenge? What Practitioners Need to Know

Brian Winrow | Tax Attorney & Professor
リアクション
2026年07月19日
The new Keysight Technologies, Inc. v. United States decision is one of the first major tax cases applying the Supreme Court's landmark decision in Loper Bright Enterprises v. Raimondo, raising important questions about whether Treasury regulations have become easier to challenge after the end of Chevron deference. In this video, Tax Attorney and Professor Brian Winrow explains what every tax practitioner needs to know about Loper Bright, Keysight, APA §706, Skidmore deference, and IRC §7805(a), and why these developments may significantly affect how federal courts review Treasury regulations going forward. You'll learn how courts now independently interpret tax statutes, why the Keysight court concluded that Treasury's general rulemaking authority under IRC §7805(a) could not expand Congress's substantive authorization, and what this decision may mean for future tax litigation, IRS guidance, and administrative law. Whether you are a CPA, EA, tax attorney, graduate tax student, accounting student, or tax professional interested in federal tax procedure, tax research, Treasury regulations, or current developments in tax law, this video provides a practical framework for understanding one of the most significant shifts in tax administration in decades.

Disclaimer: This video is provided for educational purposes only and should not be construed as legal, tax, or accounting advice. The discussion reflects the law and authorities available as of the publication date. Consult a qualified tax professional regarding your specific circumstances.

#cpa #taxlaw #enrolledagent #taxes #irs

Chapters

00:00 Introduction: Loper Bright and Keysight Technologies
02:02 Understanding IRC §7805(a), APA §706, and Chevron (1984)
06:03 Understanding Loper Bright (2024), Skidmore (1944), and Keysight Technologies (2026)
10:25 What Loper Bright and Keysight Mean for Tax Professionals

About Brian Winrow

Brian Winrow is a tax attorney and educator with extensive experience in taxation, accounting, and business. He holds a J.D., LL.M. in Taxation, DBA, MAcc, and MBA and is licensed to practice before the U.S. Tax Court. Brian teaches undergraduate and graduate-level tax and accounting courses and focuses on making complex tax concepts easy to understand. He is the founder of Winrow Tax Services, where he works with individuals and businesses on a wide range of tax matters.

For more information, visit Winrow Tax Services at www.winrowtax.com.

Have questions? Leave them in the comments. If you are interested in becoming a client, please contact info@winrowtax.com directly rather than posting confidential information in the comments.