President Donald Trump on July 4, 2025, signed into law H.R. 1, commonly referred to as the One Big Beautiful Bill Act (OBBB). (For a detailed analysis of the bill, see Holland & Knight's previous alert, "Trump Signs the One...more
In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more
6/30/2025
/ AbbVie ,
Break-Up Fee ,
Capital Losses ,
Contract Disputes ,
Cooperation Agreement ,
Corporate Taxes ,
Fees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Tax Court ,
Tax Deductions ,
Tax Planning
As of June 12, 2025, individuals and businesses can register to receive information on the Trump Gold Card – a proposed alternative or possible replacement to the EB-5 visa, also known as the Immigrant Investor Visa. ...more
Between wildfires such as the ones in Southern California earlier this year and hurricanes and other major storms experienced by other parts of the country annually, there is no shortage of natural disasters affecting people...more
4/18/2025
/ Estate Planning ,
Federal Taxes ,
Insurance Claims ,
Natural Disasters ,
Property Damage ,
Property Tax ,
Qualified Disaster Relief Payments ,
State Taxes ,
Tax Deductions ,
Tax Liability ,
Taxation ,
Time Extensions
In the Texas Top Cop Shop case, the U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued an injunction that deferred all reporting requirements under the Corporate Transparency Act (CTA). (See Holland...more
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more
The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more
The U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued a nationwide preliminary injunction suspending the government's enforcement of the Corporate Transparency Act (CTA) and its Implementing...more
12/10/2024
/ Appeals ,
Beneficial Owner ,
Business Entities ,
Commerce Clause ,
Constitutional Challenges ,
Corporate Governance ,
Corporate Transparency Act ,
Corporations Code ,
Department of Justice (DOJ) ,
FinCEN ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements
In private letter ruling (PLR) 202440007, the taxpayer (Taxpayer REIT) elected to be treated as a real estate investment trust (REIT) for its initial tax year. The Taxpayer REIT was formed as a vehicle to invest indirectly...more
The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more
1/13/2023
/ C-Corporation ,
Comment Period ,
Domestic Partnership ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Shareholders ,
Side Letters ,
U.S. Treasury
The coronavirus (COVID-19) health crisis and associated economic downturn is expected to have a significant impact on commercial real estate lessees, as their ability to attract in-person customers and otherwise generate...more