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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

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

Orrick, Herrington & Sutcliffe LLP on

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

Morrison & Foerster LLP

The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?

Morrison & Foerster LLP on

Alongside the more typical summer fare, such as coverage of the best beach reading and the latest action movie blockbuster, this summer the media have been abuzz with seemingly daily reports on the latest so-called...more

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