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Amortization Internal Revenue Service

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

Holland & Knight LLP on

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Interim Guidance on Capitalization and Amortization of Research and Experimental Expenditures Under Section 174 of the...

On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more

McDermott Will & Emery

Weekly IRS Roundup December 6 – December 10, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 6, 2021 – December 10, 2021... December 6, 2021: The IRS published updated guidance on...more

Fenwick & West LLP

New Field Attorney Advice Explores the Intersection of § 1253 with the Anti-Churning Rules of § 197

Fenwick & West LLP on

A new IRS legal advice memorandum addresses a fact pattern that may become more common in the wake of Tax Reform—sale of intangible property from a controlled foreign corporation to its United States parent—and highlights the...more

Morrison & Foerster LLP

Negative Interest Rate Consequences

Over the last few months, the financial press has been filled with reports of negative interest rates. For example, on December 18 2014, the Swiss National Bank announced that it would move from a zero percent interest rate...more

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