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GILTI tax Research and Development

BakerHostetler

Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions reached completion with Legislation signed by President Trump on July 4, 2025....more

Fenwick & West LLP

Notice 2023-63 Proposes Comprehensive Guidance on the New R&D Capitalization Requirements

Fenwick & West LLP on

Released on September 8, 2023, IRS Notice 2023-63 provides wide-ranging and potentially controversial guidance on the capitalization and amortization of research and experimentation expenses under section 174....more

McDermott Will & Emery

Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

McDermott Will & Emery on

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more

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