Corporate Taxes, Summary Judgment

Tax Court Says AbbVie's $1.6B Break Fee Payment to Shire Properly Deducted as Ordinary Expense

Fenwick & West LLP on 6/18/2025

A break fee in a merger-gone-south can be deducted as an ordinary expense, the U.S. Tax Court held today, finding for biopharmaceutical giant AbbVie and rejecting the IRS’s argument that AbbVie must treat the fee as a capital...more

Failure to Plead Fraud with Particularity, A “Single Shot Transaction” and the Lemon Law

Freiberger Haber LLP on 1/2/2024

In today’s article, we examine Eva Chen Fine Jewelry, Inc. v. Recovery Racing IX, LLC, 2023 N.Y. Slip Op. 06511 (2d Dept. Dec. 20, 2023) (here), a case involving common law fraud, New York’s lemon law and Section 349 of New...more

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

A&O Shearman on 10/24/2017

On September 29, 2017, the United States District Court for the Western District of Texas granted summary judgment in favor of the U.S. Chamber of Commerce and Texas Association of Business, holding that the Internal Revenue...more

Economic Presence Standard for Income Tax Nexus

McDermott Will & Emery on 10/7/2015

In a question of first impression for Illinois, on May 12, 2015, Judge Schmidt of the Circuit Court of Sangamon County granted a summary judgment for the Illinois Department of Revenue, holding that the proper test for...more

Beleaguered D.C. Taxpayers Achieve Another Success in Ongoing Challenges to the Methodology Used in the District’s Transfer...

McDermott Will & Emery on 11/21/2014

On Friday, November 14, 2014, an administrative law judge (ALJ) issued three identical orders granting the taxpayer’s motion for summary judgment in Hess v. OTR, Shell v. OTR and ExxonMobil v. OTR. In these orders, the ALJ...more

Corporate Taxes › Summary Judgment

Tax Court Says AbbVie's $1.6B Break Fee Payment to Shire Properly Deducted as Ordinary Expense

Failure to Plead Fraud with Particularity, A “Single Shot Transaction” and the Lemon Law

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

Economic Presence Standard for Income Tax Nexus

Beleaguered D.C. Taxpayers Achieve Another Success in Ongoing Challenges to the Methodology Used in the District’s Transfer...

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