Law Commons^™

A Domestic Disturbance: The Seventh Circuit Encroaches On Foreign Related Party Transactions, Erica S. Khalili

Seventh Circuit Review

Has deference to administrative regulation gone too far in its impact on American corporations and consequently become to great a foe to American corporations in a global marketplace? In the wake of the widespread corporate scandals, many of the regulations enacted are aimed at combating corporate fraud. Recently, in Square D Co. v. Commissioner of the Internal Revenue Service, the Seventh Circuit Court of Appeals upheld the validity of one such regulation, requiring taxpayers to utilize the cash basis method of accounting to deduct interest payments made to tax-exempt foreign related parties. This Note examines where this regulation fits …