On October 22, 2024, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited regulations implementing the advanced manufacturing investment credit under Sections 48D and 50...more
In March 2010, Congress codified the economic substance doctrine in Internal Revenue Code (Code) Section 7701(o). The codification clarified that a conjunctive analysis applies in determining if the doctrine applies. The...more