6/19/2025 10:40:08 AM The One Big Beautiful Bill Augments QSBS Benefits for Startup Founders and Investors By William Skinner Kris Hatch The One Big Beautiful Bill Act (OBBBA) was enacted into law on July 4, including the Senate bill's taxpayer-favorable changes to...
6/17/2025 10:01:11 PM Tax Court Says AbbVie's $1.6B Break Fee Payment to Shire Properly Deducted as Ordinary Expense By Vanessa Park-Thompson 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...
4/30/2025 8:48:17 PM Cuts at IRS Appeals By Vanessa Park-Thompson The IRS workforce continues to shrink, with deferred resignations of hundreds of IRS Appeals personnel. Bloomberg reports that the IRS...
4/29/2025 4:58:40 PM Key Changes in the Final and Proposed Digital Content and Cloud Computing Regulations By David Forst Kris Hatch The U.S. Department of Treasury (Treasury) released final1 and proposed2 regulations under § 861 of the Code addressing the U.S. federal...
3/24/2025 6:30:08 PM A Recent Tax Ruling Has Made ANDA Litigation Less Burdensome for Generics By Vanessa Park-Thompson In Actavis v. U.S., a case at the intersection of tax law and patent law, the Federal Circuit held that generic drug companies’...
2/6/2025 3:39:58 PM U.S. Department of Treasury’s Proposed PTEP Regulations: Key Changes and Tax Implications By Kris Hatch William Skinner The U.S. Department of Treasury (Treasury) recently released proposed regulations under §§ 959 and 961 and related Code sections...
12/27/2024 11:30:02 PM IRS Releases Final Broker Reporting Regulations for DeFi By David Forst Sean McElroy Matthew Dimon The IRS released final broker reporting regulations for DeFi transactions on December 27, 2024, effective starting January 1, 2027. The...
12/16/2024 4:00:36 PM Exxon Mobil Case is an Early Taxpayer Win in the Economic Substance Controversy By William Skinner 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...