July/August 2024, Featured, Columns, Taxation | The Loper Bright decision reverses the longstanding legal framework for evaluating an executive agency’s regulatory interpretation of a statute it administers. Pursuant to the Court’s 1984 decision in Chevron, courts were instructed to defer to the agency’s interpretation, so long as the statute was ambiguous and the agency’s interpretation was reasonable [Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (1984)].