In Mylan, Inc. & Subsidiaries v. Commissioner, 156 T.C. No. 10 (April 27, 2021), the Tax Court held that legal expenses incurred by a manufacturer of generic pharmaceutical drugs for the preparation, assembly and transmittal...more
A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
Reorganizations ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On December 22, 2017, President Donald Trump signed into law the Tax Cuts and Jobs Act (TCJA), which includes numerous changes that will significantly impact mergers and acquisitions (M&A). Although the TCJA has rightly been...more
1/19/2018
/ Acquisitions ,
Bonus Depreciation ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Interest Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Mergers ,
Multinationals ,
Net Operating Losses ,
Parent Corporation ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions
After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more
4/22/2014
/ Accounting ,
Alternative Minimum Tax ,
Corporate Taxes ,
Debt Restructuring ,
Derivatives ,
Financial Products ,
Foreign Tax ,
Internal Revenue Code (IRC) ,
Partnerships ,
Subpart F ,
Tax Credits ,
Tax Reform ,
Ways and Means Committee