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White House and Military Departments Release Guidance as (Another) Budget Deadline Approaches

Client Alert | 1 min read | 01.18.13

In the past week, OMB, DoD, Army, Air Force, and Navy have all released guidance directing their subordinate entities to begin planning for the possibility of sequestration (presently scheduled to result in the cancellation of approximately $85 billion in FY13 budgetary resources) beginning on March 1, 2013, and for the expiration of the FY13 Continuing Appropriations Resolution (which expires on March 27, 2013, and must either be extended or replaced with new appropriations acts to prevent a lapse in appropriations and government shutdown). While the guidance cautions that efforts to prevent sequestration and ensure continued appropriations are underway, the memos acknowledge that, as a practical matter, agencies must begin planning for the possibility that they will need to operate with dramatically reduced budgetary resources.


Insights

Client Alert | 3 min read | 10.07.25

Blocking the Blocked Income Rules? Loper Bright’s influence over the Eighth Circuit’s 3M decision.

On October 1, 2025, the Eighth Circuit decided 3M Co. v. Commissioner in the taxpayer’s favor, based on its application of Loper Bright. The question presented in the case was whether the IRS had the authority to reallocate royalty income to a U.S. parent company that its foreign subsidiary was prohibited from paying under foreign law. The court held that the best interpretation of the governing statute did not permit the IRS’s reallocation....