[20210712]LSB10619_最高法院在CIC ServicesLLC诉美国国税局案中的裁决影响了对美国国税局报告授权的执法前挑战.pdf

CRS Legal Sidebar Prepared for Members and Committees of Congress Legal SidebarLegal Sidebari i Supreme Courts Decision in CIC Services, LLC v. Internal Revenue Service Impacts Pre-Enforcement Challenges to IRS Reporting Mandates July 12, 2021 On May 17, 2021, the Supreme Court issued a unanimous decision in CIC Services, LLC v. Internal Revenue Service, narrowing the reach of the tax Anti-Injunction Act (AIA). The AIA provides that “no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court.” The AIA protects federal revenues and supports efficient tax administration by barring lawsuits seeking pre-enforcement judicial review of Department of the Treasury (Treasury) and Internal Revenue Service (IRS) administrative actions related to tax assessment or collection. Subject to a few exceptions that the Court deemed irrelevant in CIC Services, the AIA requires plaintiffs seeking to challenge the validity of a tax to file their lawsuits after paying the disputed tax and filing a claim for refund. In CIC Services, the petitioner, CIC Services, LLC (CIC), brought a lawsuit challenging the “lawfulness” of IRS Notice 2016-66 (Notice). Th