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
11/30/2023
/ Amortization ,
Disclosure Requirements ,
Internal Revenue Code (IRC) ,
IRS ,
Life Sciences ,
New Guidance ,
Proposed Regulation ,
Research and Development ,
Research and Experiment Tax Credit ,
SEC Comment Letter Process ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Taxation ,
Technology Sector ,
U.S. Treasury
Treasury and the IRS released final section 250 regulations on July 9, 2020, primarily focused on the deduction for foreign-derived intangible income (FDII). The final regulations make significant revisions to the proposed...more
8/17/2020
/ Applicability Date ,
Arms Export Control Act ,
CARES Act ,
Cost of Goods Sold (COGS) ,
Foreign Derived Intangible Income (FDII) ,
Foreign Persons ,
Foreign Sales ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
New Rules ,
Required Documentation ,
U.S. Treasury