[EstGift] [filtered] Committee Approval of Proposed Materials Relating to Section 2702 for Priority Guidance Plan and Upcoming Summer Meeting [IMAN-WEALTHMGMT.FID578316]

[Cohen, Kimberly E.]

E&G Tax Committee Members,

As I promised in my May 6th email, attached please find the proposed submission by the Washington Affairs Committee to Treasury and the IRS on the existing regulations under § 2702, suggesting that they violate Loper Bright.  Thank to our member Caryln McCaffrey for her efforts in putting this material together.

Please share any comments, questions, or objections on the following two items by Wednesday, May 20.

Furthermore, for those of you whom will be joining us at the Boston summer meeting, Carlyn will be leading a discussion on other regulations that may be in violation of Loper Bright.  I ask that each of you spend some time thinking about whether there are regulations you would like to discuss during the meeting that you think may be (i) unconstitutional, (ii) based on unlawful delegations of legislative power, and (iii) those based on anything other than the best reading of the underlying statute.  There are some materials relating to this starting at page 99 of the PDF of the Summer meeting in Montreal.

Thanks,
-Kim


Kimberly E. Cohen
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