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12.19.2025

Firm Publication

IRS Clarifies Sourcing Rules for Borrow Fees in Securities Lending Transactions

Tax Alert

12.19.2025

Firm Publication

Final Regulations on Stock Buyback Excise Tax Remove "Funding Rule" Among Other Revisions

Tax Alert

10.10.2025

Firm Publication

Recent Case Law Highlights Potential Variance Doctrine Pitfalls

Tax Alert

10.10.2025

Firm Publication

Treasury and IRS Withdraw Controversial Spin-off Guidance

Tax Alert

08.06.2025

Firm Publication

OBBBA Brings 45X Changes, Though Not Wholesale Repeal

Tax Alert

08.06.2025

Firm Publication

Tax Court Invalidates Treasury Regulation Addressing BBA Partnership Audit Rules

Tax Alert

06.13.2025

Firm Publication

Novel Tax Court Interpretation of Section 461(h) Economic Performance Requirement

Tax Alert

06.13.2025

Firm Publication

IRS Notches Another Win Over the Limited Partner Exception to Self-Employment Tax

Tax Alert

05.13.2025

Firm Publication

The Reportable Transaction Retreat Has Begun… Where Will it End?

Tax Alert

03.12.2025

Firm Publication

Suspended Losses Preclude Tax Court from Hearing Accounting Method Change Dispute

Tax Alert

03.12.2025

Firm Publication

Proposed Section 355 Regulations Address Delayed Distributions and Add Reporting Requirements

Tax Alert

03.04.2025

External Publication

Exam: IRS' Enhanced Enforcement Efforts for Partnerships and High-Net-Worth Individuals

02.13.2025

Firm Publication

Treasury and the IRS Release Foreign Tax Credit Guidance for Digital Content Transfers and Cloud Services Transactions

Tax Alert

01.16.2025

Firm Publication

IRS Provides Additional Relief for Method Changes Involving Section 174 Expenses

Tax Alert

01.16.2025

Firm Publication

IRS Releases Draft Instructions for Revised R&E Credit Form

Tax Alert

01.16.2025

Firm Publication

Employee Retention Credits Continue to Be a Sore Spot for Taxpayers and the IRS

Tax Alert

01.16.2025

Firm Publication

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

Tax Alert

12.12.2024

Firm Publication

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

Tax Alert

12.12.2024

Firm Publication

IRS Extends Transition Period for R&D Credit Refund Claims

Tax Alert

11.04.2024

Firm Publication

Section 45X Final Regulations Expand Credit-Eligible Production Cost Activities

Tax Alert

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publications

IRS Clarifies Sourcing Rules for Borrow Fees in Securities Lending Transactions

Final Regulations on Stock Buyback Excise Tax Remove "Funding Rule" Among Other Revisions

Recent Case Law Highlights Potential Variance Doctrine Pitfalls

Treasury and IRS Withdraw Controversial Spin-off Guidance

OBBBA Brings 45X Changes, Though Not Wholesale Repeal

Tax Court Invalidates Treasury Regulation Addressing BBA Partnership Audit Rules

Novel Tax Court Interpretation of Section 461(h) Economic Performance Requirement

IRS Notches Another Win Over the Limited Partner Exception to Self-Employment Tax

The Reportable Transaction Retreat Has Begun… Where Will it End?

Suspended Losses Preclude Tax Court from Hearing Accounting Method Change Dispute

Proposed Section 355 Regulations Address Delayed Distributions and Add Reporting Requirements

Exam: IRS' Enhanced Enforcement Efforts for Partnerships and High-Net-Worth Individuals

Treasury and the IRS Release Foreign Tax Credit Guidance for Digital Content Transfers and Cloud Services Transactions

IRS Provides Additional Relief for Method Changes Involving Section 174 Expenses

IRS Releases Draft Instructions for Revised R&E Credit Form

Employee Retention Credits Continue to Be a Sore Spot for Taxpayers and the IRS

Treasury Publishes Final Regulations for Supervisory Approval of Penalties

Treasury and IRS Release Long-Awaited Proposed Regulations on Previously Taxed Earnings and Profits

IRS Extends Transition Period for R&D Credit Refund Claims

Section 45X Final Regulations Expand Credit-Eligible Production Cost Activities

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