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Fees › Tax Deductions

Holland & Knight LLP

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

Holland & Knight LLP on

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

Orrick, Herrington & Sutcliffe LLP

Washington State enacts provisions to allow companies to deduct interchange fees

Orrick, Herrington & Sutcliffe LLP on

On May 20, the governor of Washington State signed into law HB 2020 which amends the state’s tax laws to exclude interchange fees from the business and occupation tax. The legislation stemmed from a lawsuit where a company...more

Allen Barron, Inc.

IRS Warns of Shady Tax Preparers and Increased Audit Risk

Allen Barron, Inc. on

In a recently released bulletin, IR-2023-59, the IRS warns of shady tax preparers and increased audit risk as part of their “Dirty Dozen” series.  The IRS provided some common “warning signs” including tax preparers who base...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Determined a Subsidiary Stock Sale Does Not Make Prior Capitalized Transaction Costs Deductible

Skadden, Arps, Slate, Meagher & Flom LLP on

A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more

Troutman Pepper Locke

Transaction Cost Deduction Denied - Tax Court Found Finder's Fee Paid By Target Was Not Paid For Benefit Of Target - Tax Update:...

Troutman Pepper Locke on

Plano Molding Co. (target), a manufacturer of plastics, was acquired by Plano Holding, an affiliate of the Ontario Teachers’ Pension Plan Board (buyer), from Tinicum Capital Partners (seller). ...more

Williams Mullen

Final Regulations Issued For Investment Advisory Fees and Other Costs Incurred By Trusts and Estates Subject to the 2-Percent...

Williams Mullen on

On May 8, 2014, the Internal Revenue Service published final Treasury Regulations, §1.67-4, prescribing when costs incurred by estates or nongrantor trusts are subject to the 2-percent floor for miscellaneous itemized...more

Proskauer - Employee Benefits & Executive...

IRS Says PCORI Fees Are Deductible

Proskauer - Employee Benefits & Executive... on

As employers plan for paying various health care reform fees, one question that arises is whether the fees owed are tax deductible. In particular, it has been unclear whether the fees paid pursuant the Affordable Care Act to...more

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