Tax Law

Recent Posts

Container Corp. v. Comm’r: Clarity on Guarantee Fee Sourcing?
Posted on 8 Dec 2010 by Rufus Rhoades

Editor's Note : The following is an excerpt from Rhoades & Langer U.S. International Taxation and Tax Treaties § 26.01[3][f] (Matthew Bender). ... The question of how to treat guarantee fees has long vexed both practitioners and the... Read More

Supreme Court's Decision on the Patent Eligibility of Process Claims
Posted on 8 Jul 2010 by Eric E Bensen

Editor's Note : Bilski v. Kappos, 2010 U.S. LEXIS 5521 (U.S. June 28, 2010) changes the landscape on the patentability of business methods and has direct relevance to the viability of patenting for tax strategies. The impact of Bilski in this regard... Read More