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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, Scott H. Rabinowitz, David A. Schneider

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

USA - February 5 2020 A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under…

Scott H. Rabinowitz, David A. Schneider

IRS Issues Guidance Regarding Virtual Currency Transactions

USA - October 17 2019 On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as…

Su Da, Nathan W. Giesselman, Edward E. Gonzalez, Diana M. Lopo

Proposed bonus depreciation regulations clarify impact on certain transactions

USA - August 20 2018 The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus…

Jay P. Cosel, Scott H. Rabinowitz, David A. Schneider

South Dakota v. Wayfair, Inc.

USA - June 22 2018 The U.S. Supreme Court upended 51 years of precedent on Thursday, June 21, 2018, when it held in a 5-4 decision that a state can require an online…

Christopher P. Bowers, Carl R. Erdmann, David F. Levy, Eric B. Sensenbrenner