A recent memo from the IRS's Large Business and International (LB&I) Division indicates an intention to resolve audits efficiently and...

The One Big Beautiful Bill Act (OBBBA) was enacted into law on July 4, including the Senate bill's taxpayer-favorable changes to...

A break fee in a merger-gone-south can be deducted as an ordinary expense, the U.S. Tax Court held today, finding for biopharmaceutical...

The IRS workforce continues to shrink, with deferred resignations of hundreds of IRS Appeals personnel. Bloomberg reports that the IRS...

The U.S. Department of Treasury (Treasury) released final1 and proposed2 regulations under § 861 of the Code addressing the U.S. federal...

In Actavis v. U.S., a case at the intersection of tax law and patent law, the Federal Circuit held that generic drug companies’...

The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections...

The IRS released final broker reporting regulations for DeFi transactions on December 27, 2024, effective starting January 1, 2027. The...

Recently, in Exxon Mobil Corp. v. United States (No. 3:22-cv-00515), a District Court in Texas ruled that the taxpayer was entitled to...