News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Tax Deductions

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

Ballard Spahr LLP on

It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Foster Garvey PC

Hobby Loss Rules Revisited

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With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Axinn, Veltrop & Harkrider LLP

Federal Circuit Holds Generic’s Hatch-Waxman Litigation Expenses Deductible

A March 21 Federal Circuit decision in Actavis Laboratories FL, Inc. v. United States, No. 23-1320 (Fed. Cir. Mar. 21, 2025) marked a victory for generic drug developers, affirming that legal expenses incurred defending...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Goodwin

Federal Circuit Confirms Deductibility of Hatch-Waxman Litigation Expenses

Goodwin on

On March 21, the Court of Appeals for the Federal Circuit held in a precedential opinion that legal fees incurred by generic drug companies in defending against patent infringement suits brought under the Hatch-Waxman Act...more

Fenwick & West LLP

A Recent Tax Ruling Has Made ANDA Litigation Less Burdensome for Generics

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In Actavis v. U.S., a case at the intersection of tax law and patent law, the Federal Circuit held that generic drug companies’ Hatch-Waxman litigation expenses are “ordinary and necessary business expenses” and can be...more

Rivkin Radler LLP

Transferring the Family Business To A Private Foundation? Are You Sure About That?

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Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more

Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

Williams Mullen on

On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Seyfarth Shaw LLP

The Week in Weed: February 2025 # 2

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Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana. This week, we look at a new proposal that would prevent cannabis companies from deducting business expenses, even if...more

Katten Muchin Rosenman LLP

International Philanthropy: Considerations for the Globally Minded Donor

Many of our clients are interested in engaging in global philanthropy. These individuals often want to benefit charitable causes outside of the United States while still being able to maintain an income tax deduction for...more

Bradley Arant Boult Cummings LLP

Not Cool, Man: Senate Proposal to Expand 280E Taxes on Cannabis Businesses Even if Rescheduled

Anyone who thought that the momentum towards federal liberalization of marijuana would be a straight line found themselves with a cold dash of water to the face. Late last week Republican senators filed a bill, entitled the...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

Freeman Law on

Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more

Groom Law Group, Chartered

IRS Provides Tax Guidance Related to State-Run Paid Family and Medical Leave Programs

On January 16, 2025, the Internal Revenue Service (“IRS”) issued Revenue Ruling 2025-4 (the “Rev. Rul.”). The Rev. Rul. provides guidance on the federal tax treatment of contributions to and benefits paid under a state paid...more

Shook, Hardy & Bacon L.L.P.

Tax Considerations for Settlement Negotiations

Settlements in the employment law context can set up thorny tax issues for employers. In this alert, we will discuss two key issues companies should consider when working toward a settlement agreement: the deductibility of...more

Husch Blackwell LLP

Employer Strategies for Assisting Employees Amidst California Wildfires: Qualified Disaster Relief Payments

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High winds and drought conditions have fueled severe wildfires, devastating communities around Los Angeles, California. The fires have destroyed thousands of homes and businesses, while firefighters are working tirelessly to...more

Seyfarth Shaw LLP

How Now, High Five? IRS Issues Proposed Regulations for the Expanded Definition of “Covered Employee” Under Section 162(m) that...

Seyfarth Shaw LLP on

On January 16, 2025, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code of 1986 (the “Code”), which limit the amount of compensation a publicly held corporation may deduct for wages paid to...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Need to be vigilant on keeping those 401(k) deferrals

With a new administration in the White House, tax legislation will certainly be on the plate. As we know with the last tax bill, great tax deductions and subsidies could be on the chopping block to pay for tax cuts. ...more

Offit Kurman

The Top 10 Mistakes Made When Planning for Art and Other Collectibles: A Guide for Professionals and Their Clients - Mistake #1

Offit Kurman on

Navigating the tax landscape for art dealers, investors, and collectors can be a complex endeavor, but proper classification is key to maximizing tax savings and avoiding pitfalls....more

Proskauer Rose LLP

Wealth Management Update - January 2025

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The January 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.2%, an increase from the December 2024 rate of 5.0%. The January applicable federal rate (“AFR”) for use with...more

DarrowEverett LLP

The Tax Implications of Divorce: Alimony, Child Support, IRAs and More

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Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and...more

McDermott Will & Emery

Weekly IRS Roundup October 28 – November 1, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28, 2024 – November 1, 2024....more

McDermott Will & Emery

Weekly IRS Roundup October 7 – October 11, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7, 2024 – October 11, 2024. ...more

Foster Garvey PC

A Birthday Greeting to the Tax Reform Act of 1986

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The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in...more

McDermott Will & Emery

Weekly IRS Roundup August 26 – August 30, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more

McDermott Will & Emery

Weekly IRS Roundup August 19 – August 23, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19, 2024 – August 23, 2024. August 19, 2024: The IRS released Internal Revenue Bulletin...more

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