Stay updated with breaking news from Field Attorneys. Get real-time updates on events, politics, business, and more. Visit us for reliable news and exclusive interviews.
On October 15, 2021, the IRS published Information Release 2021-203, based on Memorandum 20214101F (the "Memorandum") prepared by Field Attorneys in the Office of Chief Counsel, setting...
To embed, copy and paste the code into your website or blog: On April 27, 2021, the United States Tax Court held that legal fees incurred by generic drug manufacturers in connection with “Section 271(e)(2)” patent infringement suits are deductible as ordinary business expenses and need not be capitalized. The opinion contradicts longstanding IRS field advice, and has potential applicability to generic drug manufacturers and others who have capitalized legal fees in recent years. Such Section 271(e)(2) suits are brought in response to a generic drug manufacturer’s filing of an abbreviate...