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Corporate Taxes › Internal Revenue Service › Technology Sector

A&O Shearman

IRS Permits First Spin-off of R&D Intensive Business With No Pre Spin-off Income

A&O Shearman on

On February 28, 2020, the Internal Revenue Service (the “IRS”) released PLR 202009002, the first private letter ruling that will potentially permit a tax-free spin-off of a research and development (“R&D”) intensive business...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Skadden, Arps, Slate, Meagher & Flom LLP on

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

Orrick, Herrington & Sutcliffe LLP on

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Technology Industry?

Schwabe, Williamson & Wyatt PC on

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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