News & Analysis as of

IRS Disregards Own Revenue Ruling in Barnes Decision

The Court of Appeals for the Second Circuit recently affirmed the Tax Court’s 2013 decision in Barnes Group, Inc. and Subsidiaries, T.C. Memo 2013-109, in which the Tax Court applied the step transaction doctrine to...more

IRS Rules That Some Basis in Solar System Must Be Allocated to Structural Functions

On October 31, the IRS released Private Letter Ruling 201444025, which was addressed to a manufacturer of solar systems that are mounted on real estate. The nature of the real estate, along with many other interesting facts,...more

Disregarded Entity May Select Different Accounting Method than its Owner

In a recent Chief Counsel Advice (“CCA”), the IRS determined that a disregarded entity for federal income tax purposes (the “LLC”) operated a separate and distinct trade or business from that of its owner (the “Company”) and...more

IRS Ruling Addresses Application of Medical Device Excise Tax in Contract Manufacturing Arrangement

In Private Letter Ruling 201420004 (released May 16, 2014), the Internal Revenue Service (IRS) has ruled on the question of which party in a contract manufacturing arrangement is the "manufacturer" for purposes of the medical...more

IRS Clarifies Manufacturing Exception, addresses Contract Manufacturers

In a recent private letter ruling, PLR 201340010, the Internal Revenue Service (the “IRS”) provides us with insights into meeting the “manufacturing exception” for foreign base company sales income (“FBCSI”) under § 954(d) of...more

IRS Addresses Whether Publisher Is “Producer” Under §199

In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more

Qualifying Advanced Energy Project Program: IRS Announces Second Phase

The IRS has announced the second phase of the qualifying advanced energy project program to distribute the Section 48C tax credits that are available for reallocation now that the first phase of the program has been completed...more

Excise Tax Kicks In Jan. 1 On Certain Medical Devices

Beginning January 1, 2013, manufacturers and importers of certain medical devices will be required by the U.S. Internal Revenue Service (IRS) to pay a new 2.3 percent medical device excise tax on the sales of taxable medical...more

Foley Hoag and AdvaMed Collaborate on Industry Guidance on Retail Exemption in Final Device Tax Regulations

Foley Hoag and the Advanced Medical Technology Association (AdvaMed) collaborated on an important resource guiding manufacturers, importers, and producers of taxable medical devices through the newly released Internal Revenue...more

IRS Releases Final Rule on Medical Device Tax

Last week, the IRS and the Treasury Department published final regulations regarding the medical device excise tax under § 4191 of the Internal Revenue Code (IRC). IRC § 4191, which was enacted by the Health Care and...more

Medical Devices To Be Taxed: Manufacturers and Importers Be Prepared

Beginning January 1, 2013, manufacturers, producers, and importers of medical devices must report and pay a 2.3% excise tax on the sales price of taxable medical device pursuant to Section 4191 of the Internal Revenue Code...more

New Rules Will Be “Taxing” On Medical Device Manufacturers

The U.S. Department of the Treasury and the Internal Revenue Service (IRS) recently issued much-anticipated final regulations under Section 4191 of the Internal Revenue Code (Code), which imposes a 2.3% tax on sales of any...more

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