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Current events

  • 10/26/11. Ways and Means Committee Chair Camp (R-MI) issued a proposal to reduce the top corporate tax rate to 25% and move from a worldwide system of taxation to a territorial system.
  • 11/29/11. Internal Revenue Service issued advice that taxpayer’s costs of obtaining FDA licenses to market and sell generic drugs before expiration of patents are IRC § 263A costs subject to capitalization. FAA 20114703F. The Service’s reasoning (the company’s drugs would not be produced if they could not be marketed and sold) is inconsistent with the holding in the Robinson Knife case.