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Recent Release of Updated Procedures for Section 355 Private Letter Rulings

The US Department of the Treasury (Treasury Department) and the IRS recently released Revenue Procedure 2024-24 (Revenue Procedure) and Notice 2024-38 (Notice) establishing revised standards and procedures for taxpayers...more

IRS Clarifies Guidance on Treatment of Research, Experimentation Expenditures

The IRS recently released Notice 2024-12, which provides some clarifications and modifications to prior IRS guidance relating to the tax treatment of specified research and experimentation (SRE) expenditures pursuant to...more

IRS Publishes Guidance on Tax Rules for Software Development, Research Expenses

The Tax Cuts and Jobs Act of 2017 (TCJA) introduced significant changes to the tax treatment of specified research and experimentation (SRE) expenditures. Historically, companies were able to immediately deduct all costs...more

Startups, Other R&D-Heavy Companies May Face Significantly Higher Tax Costs in 2022

The Tax Cuts and Jobs Act was enacted more than five years ago, but certain changes under the legislation are only now coming into focus as taxpayers prepare their 2022 tax returns. In particular, there are significant...more

Blog: Court Gives Energy Transfer the Right to Walk Based on its Counsel’s Inability to Deliver the Required Tax Opinion

In a rare decision involving unusual facts, the Delaware Court of Chancery held that a buyer (Energy Transfer Equity, L.P.) had the right to terminate a signed merger agreement with its target (The Williams Companies, Inc.)...more

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