Susan E. Ryba
Subscribe to Susan E. Ryba's PostsSusan E. Ryba focuses her practice on federal tax controversy matters and tax litigation, particularly advising clients in the technology, healthcare and pharmaceutical sectors, as well as high-net-worth individuals. Read Susan Ryba's full bio.
Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges
By Timothy S. Shuman, Susan E. Ryba, Parisa M. Griess and Samuel J. Preston on Jul 10, 2024
Posted In Court Procedure Matters
On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a pillar of US administrative law for four decades, required courts to defer to an agency’s reasonable interpretation of an ambiguous statute even where the court...
Continue Reading
United States v. Eaton: IRS Summons Power Overrides EU Privacy Laws
By Edward L. Froelich and Susan E. Ryba on May 31, 2024
Posted In Court Procedure Matters, IRS Audits, Trial Courts
A US federal district court judge recently endorsed the broad investigative powers of the Internal Revenue Service (IRS) in United States v. Eaton Corp., No. 1:23-mc-00037, May 16, 2024 (N.D. Ohio). During its audit of Eaton’s transfer pricing of a royalty arrangement with Eaton’s Irish affiliate, the IRS sought performance evaluations of certain employees of...
Continue Reading
