On May 12, 2025, the Republicans on the House Committee on Ways and Means released a draft bill showing their tax plan for the budget reconciliation legislation. The legislation will likely undergo significant changes as it...more
The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
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
On September 8, 2023, the Department of Treasury (the Treasury) and the Internal Revenue Service (the IRS) released Notice 2023-63 (the Notice), which sets forth the Treasury and the IRS’s intent to issue proposed regulations...more
The Tax Cuts and Jobs Act (TCJA) included a sunset provision for immediate expensing of research and experimentation (R&E) expenditures, generally providing that such expenses would be subject to five-year (domestic R&E) or...more
As Congress faces a March 11 deadline to enact a Fiscal Year 2022 omnibus spending bill, advocates are making their case to federal legislators this week to include a tax title that delays or repeals the five-year...more
Buyers often prefer to structure family business acquisitions as taxable asset purchases. In a taxable asset purchase, the buyer is entitled to write up the basis of the seller’s assets to fair market value, and then going...more