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The Tax Court Offers a Mixed Bag in the Mylan Case

USA - May 6 2021 In Mylan, Inc. & Subsidiaries v. Commissioner, 156 T.C. No. 10 (April 27, 2021), the Tax Court held that legal expenses incurred by a manufacturer of…

Scott H. Rabinowitz

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

USA - February 18 2021 On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of…

Scott H. Rabinowitz

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

USA - January 8 2021 On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the…

Scott H. Rabinowitz

Highlights From the Recently Issued Proposed Regulations Under Sections 162(f) and 6050X

USA - May 28 2020 On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal…

Paige D. Braddy, Steven J. Matays, Scott H. Rabinowitz

IPO Costs Are Nondeductible Even When a Corporation Later Goes Private

USA - May 27 2020 A corporation may not deduct previously capitalized costs that facilitated an initial public offering (IPO) even when it later ceases to be a publicly…

Sanessa S. Griffiths, Scott H. Rabinowitz