Case Updates
Fourth Circuit holds that pre-merger entities are separate taxpayers for the purpose of post-merger interest netting
July 29, 2025
U.S. Chamber files coalition amicus brief urging Fourth Circuit to hold that the Tax Code permits post-merger entities to net interest for overpayments and underpayments made by their pre-merger predecessors
May 28, 2024
U.S. Chamber Coalition Amicus Brief
Lauren Willard Zehmer, Kandyce Jayasinghe, and Daniel G. Randolph of Covington & Burling LLP served as outside counsel.
Case Documents
- U.S. Chamber Coalition Amicus Brief -- Bank of America v. United States (4th Cir.)
- Opinion -- Bank of America v. United States (4th Cir.)