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
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
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