Keysight v. United States: Federal Court Strikes GILTI Regulations Under Loper Bright, Implications for State Tax Agencies

Short summary

The U.S. Court of Federal Claims struck down Treasury GILTI regulations in Keysight v. United States, applying the Supreme Court's Loper Bright ruling that courts must independently judge agency authority. The court rejected Treasury's reliance on both general and specific rulemaking authority, finding the agency exceeded its statutory mandate. State tax professionals should treat this as a signal that analogous state-level agency deference doctrines may also face challenges.

• •Federal Claims Court struck down Treasury GILTI regs under Loper Bright framework
• •Court rejected both general (IRC §7805) and specific statutory authority arguments
• •State tax professionals should expect similar challenges to state agency deference doctrines

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