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Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

Jones Day on

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

Polsinelli on

In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more

Rivkin Radler LLP

Bona Fide Intercompany Loan – Are You Sure?

Rivkin Radler LLP on

Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more

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