The One, Big, Beautiful Bill Act (H.R. 1), recently passed by the U.S. House, introduces major changes to the Global Intangible Low-Taxed Income (GILTI) regime that could impact multinational corporations...
Class B malls have struggled in recent years with the decrease in mall shoppers and the departure of anchor tenants. Developers and owners are revitalizing Class B malls and filling vacancies by introducing...
Joint ventures bring together two or more parties to collaborate on a specific business opportunity. They may be structured as contractual arrangements, new entity formations, or investments in an existing...
This practice note covers how to respond to a complete response letter issued by the FDA as part of the agency’s new drug application (NDA) or biologics license application (BLA) process. Read...
Want to know how to balance the benefits of artificial intelligence tools against associated risks to employee privacy? Read our practice note, Artificial Intelligence (AI) and Employee Privacy , by Damon...
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The 2024 landmark case, Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244 (June 28, 2024), officially jettisoned the 40-year-old Chevron two-step standard for statutory interpretation. Will Loper Bright motivate the Treasury Department and IRS to now avoid formal rulemaking and shift to more informal guidance that can be issued quickly without notice and comment? Post Loper Bright, will judges continue to find tax regulations persuasive and adopt the government's interpretation? For reference, one recent U.S. Tax Court Judge indicated a belief that the "Tax Court will continue to lend considerable credence to agencies' rules" due to Treasury and the IRS's "special competence in drafting tax regulations." See CRS, Reliance on Treasury Department and IRS Tax Guidance.
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