Don’t Leave Me This Way! Loper Bright Upends Regulatory Interpretation

In Loper Bright and Relentless, the Supreme Court expressly overruled Chevron U.S.A. v. National Resources Defense Council, Inc., which had required federal courts to defer to reasonable regulatory interpretations of ambiguous statutory provisions. Now, when an interpretive regulation is challenged, courts will be required to apply traditional canons of statutory construction to arrive at their own interpretations of the underlying provisions of the Internal Revenue Code rather than deferring to what’s reflected in the regulation.

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Related Content

• U.S. Supreme Court: Chevron Overruled
  Read how the Supreme Court, in overruling Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc., now holds that the Administrative Procedure Act requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority. Courts may not defer to an agency interpretation of the law simply because a statute is ambiguous.

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