Federal Court Strikes Down Treasury's GILTI Regulation, Citing Supreme Court's 'Loper Bright' Decision

The U.S. Court of Federal Claims ruled that the Department of the Treasury exceeded its statutory authority in issuing Treasury Regulation Section 1.951A-2(c)(5), which implements global intangible low-taxed income (GILTI) provisions. This decision marks one of the first major applications of the Supreme Court's 'Loper Bright Enterprises v. Raimondo' ruling, which struck down 'Chevron deference' and requires courts to independently judge whether an agency acted within its statutory authority.