Corporate Taxes, Internal Revenue Code (IRC), Tax Court

Tax Bytes: Week of July 14, 2025

Eversheds Sutherland (US) LLP on 7/16/2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

AbbVie Catches a Break in Termination Fee Tax Court Case

Cadwalader, Wickersham & Taft LLP on 6/30/2025

On June 17, the U.S. Tax Court ruled that AbbVie, Inc. could deduct the fee it paid to terminate its 2014 combination agreement with Shire plc. This decision represents a significant win for AbbVie, and it represents a...more

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

Holland & Knight LLP on 6/30/2025

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

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

Rivkin Radler LLP on 6/11/2025

An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

IRS Roundup May 15 – June 2, 2025

McDermott Will & Schulte on 6/6/2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025....more

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on 1/29/2025

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on 2/15/2024

Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

Tax Court in Brief | Ismail v. Comm’r | Foreign LLC for U.S. tax purposes; Substantiation of Schedule C Expenses; Section 274

Freeman Law on 1/3/2023

Short Summary: The case discusses the tax classification of a foreign corporation for U.S. tax purposes and the substantiation of various business expenses such as vehicle, travel, and meals and entertainment expenses....more

Tax Court in Brief – Slone v. Commissioner

Freeman Law on 2/14/2022

Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Slone v. Commissioner Slone v. Comm’r, T.C. Memo 2022-6 | February 7, 2022 | Lauber, J. | Dkt. Nos. 6629-10, 6630-10, 6631-10, 6632-10...more

The Tax Court in Brief - September 2021 #2

Freeman Law on 10/8/2021

Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more

The Tax Court in Brief - November 2020

Freeman Law on 11/24/2020

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

Orrick, Herrington & Sutcliffe LLP on 6/21/2019

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

Loughman Case Illustrates Potential Impact of Entity Choice on Income Tax Liability for Cannabusinesses

Rosenberg Martin Greenberg LLP on 2/22/2019

Recognition of Internal Revenue Code (“I.R.C.”) § 280E and its potential to limit deductions can have a material impact on the ongoing operation of a cannabusiness. While operational concerns require attention, improper tax...more

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on 9/28/2018

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Altera: Ninth Circuit Reverses US Tax Court and Holds that Treasury Regulation Allocating Stock-Based Compensation Expenses Is...

A&O Shearman on 7/31/2018

On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

Foley & Lardner LLP on 3/15/2017

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

Coblentz Patch Duffy & Bass on 10/12/2016

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

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