In with the New – In with the Old: TJCA Allows for Full Expensing of New and Old Depreciable Property; Lower Tax Rates for Certain Sales to Foreign BuyersThere has always been a tension between buyers and sellers as to whether to structure a negotiated M&A transaction as a “stock sale” or an “asset sale”
Much has been made of the question of liability for the operation or furnishing of digital platforms in the copyright context. Since the U.S. Supreme Court ruling that the provider of the Betamax recorder did not itself infringe copyright in the movies some users illegally copied on it (because the...
Reasonable Cause Defense Waives Privilege?
In the pending Eaton transfer pricing advance pricing agreement (APA) case the court ordered that Eaton waived privilege and work product protections needed to withhold documents as a consequence of the company asserting the reasonable cause defense. The...