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A lawsuit recently was filed challenging an assessment of franchise and excise tax resulting from the Department of Revenue’s disallowance of expenses paid to an affiliate.

Interest Deductibility - Video

Ofer Lion was quoted in a December 3 story from Tax Notes Today entitled "Court Wrangling Persists Over California Donor Disclosure Rule" on upcoming arguments...

H. David Rosenbloom examines the complexities of Pillar Two and the "Side-by-Side" Agreement in international tax law, providing clarity on these intricate mechanisms. This analysis explores the technical framework and implications of these global tax reform measures for multinational enterprises and tax practitioners.

The bill is now expected to be released tomorrow.

H. David Rosenbloom co-authored an article examining the international tax provisions of the OBBBA legislation, providing a comprehensive nutshell explanation of these complex regulatory measures. The piece offers detailed analysis of how these provisions impact cross-border taxation and international tax planning strategies.

While not specific to mergers and acquisitions, the One Big Beautiful Bill Act, passed in 2025, contains tax provisions set to impact the structure, valuation, and negotiation of M&A deals.

On April 4, 2016, the U.S. Treasury issued temporary regulations to make it increasingly difficult for companies to invert.

In a recent Law360 article, Kat Gregor provides insight on the Ninth Circuit's ruling in the Altera case.

Congress completed a flurry of last-minute tax bills on Dec. 16 by sending the president legislation that will retroactively restore nearly all of the tax provisions that expired at the end of 2013.

As an individual or business, it is your responsibility to be aware of and to meet your tax filing/reporting deadlines.

As I previously discussed, the federal tax due date for partnership and corporate tax returns changed for tax years on or after 2016.

The IRS has issued a private letter ruling (PLR 2012-28-023) taking the unusual position of applying the open transaction doctrine and ruling that no debtor corporation in a consolidated group filing for Chapter 11 bankruptcy would realize COD (cancellation of debt) income until either the debtor corporation made all the distributions required under the bankruptcy plan or the bankruptcy plan ceased to be a plan of liquidation for federal income tax purposes.

The IRS issued amendments (T.D. 9713) to the regulations under Section 6045A to delay until 2016 the new broker basis and premium reporting requirements that apply to transfers of debt instruments.

The IRS proposed regulations on Jan. 16 that will offer many taxpayers new opportunities to claim R&D tax credits for software that previously would have been excluded under the internal use software rules.

These regulations concern management fee waivers and may significantly affect certain private equity fund arrangements.