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Key tax considerations in spin-offs

McDermott Will & Emery
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USA
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April 29 2013

A critical consideration in the disposition of any business is the tax cost. If properly structured, a disposition structured as a spin-off can be

IRS updates Notice determining when construction begins for purposes of the production tax credit and investment tax credit

McDermott Will & Emery
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USA
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April 26 2013

Last week, we reported that the Internal Revenue Service (IRS) issued Notice 2013-29 (Notice) to to provide guidance on eligibility for the

Key energy-related tax provisions in the 2014 budget proposal

McDermott Will & Emery
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USA
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April 23 2013

President Obama's recently released budget proposal for the 2014 fiscal year contains energy-related tax provisions that include a permanent

IRS issues notice to determine when construction begins for purposes of production tax credit, investment tax credit

McDermott Will & Emery
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USA
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April 23 2013

The Internal Revenue Service (IRS) has issued important guidance to determine when construction begins with respect to a qualified facility for

Taxpayer challenges validity of IRS transfer pricing regulation

McDermott Will & Emery
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USA
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April 18 2013

In a petition recently filed in the U.S. Tax Court, a taxpayer has challenged the Internal Revenue Service (IRS) regulation that provides that the

IRS determines when "construction begins" for purposes of production tax credit and investment tax credit

McDermott Will & Emery
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USA
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April 18 2013

The Internal Revenue Service (IRS) issued Notice 2013-29 to provide guidance on eligibility for the production tax credit (PTC) and the investment

IRS issues procedures for securing favorable opinions on pre-approved 403(b) programs

McDermott Will & Emery
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USA
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April 17 2013

The Internal Revenue Service (IRS) recently released a revenue procedure establishing a new program for the pre-approval of 403(b) plans. The program

IRS capitalized legal fees incurred by pharmaceutical company

McDermott Will & Emery
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USA
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April 15 2013

In a recently released Field Attorney Advice, the Internal Revenue Service (IRS) Office of Chief Counsel concluded that a pharmaceutical company must

Venture funds: don’t fear the LLC

McDermott Will & Emery
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USA
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April 15 2013

It has long been the case that venture funds (classified as partnerships for tax purposes) have insisted that limited liability companies (LLCs

IRS addresses whether publisher is “producer” under 199

McDermott Will & Emery
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USA
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April 5 2013

In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher's activities in producing an "electronic" version of

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Search results

Key tax considerations in spin-offs

IRS updates Notice determining when construction begins for purposes of the production tax credit and investment tax credit

Key energy-related tax provisions in the 2014 budget proposal

IRS issues notice to determine when construction begins for purposes of production tax credit, investment tax credit

Taxpayer challenges validity of IRS transfer pricing regulation

IRS determines when "construction begins" for purposes of production tax credit and investment tax credit

IRS issues procedures for securing favorable opinions on pre-approved 403(b) programs

IRS capitalized legal fees incurred by pharmaceutical company

Venture funds: don’t fear the LLC

IRS addresses whether publisher is “producer” under 199

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