Brian Moore
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IRS Issues Final Rules on Intangible Property Repatriations
By Brian Moore on Oct 31, 2024
Posted In Uncategorized
With the allure of tax incentives for foreign derived intangible income and an increase in foreign audits scrutinizing transfer pricing, bringing intellectual property (IP) back to the United States is increasingly attractive. Newly issued final IP repatriation regulations make the tax consequences of repatriating previously offshored IP more predictable and eliminate the risk of potential...
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Tax Court Allows Partial Deduction, Requires Partial Capitalization of Generic Drug Approval Legal Expenses
By Brian Moore on May 13, 2021
Posted In Patents
The US Tax Court determined that a pharmaceutical manufacturer’s legal expenses incurred to defend against a patent infringement suit were eligible for an immediate deduction as ordinary and necessary business expenses, while legal expenses incurred as part of an abbreviated new drug application (ANDA) were not eligible for an immediate deduction and thus had to...
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