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Articles 1 - 2 of 2
Full-Text Articles in Law
Macniven V. Westmoreland And Tax Advice Using “Purposive Textualism” To Deal With Tax Shelters And Promote Legitimate Tax Advice, Scott A. Schumacher
Macniven V. Westmoreland And Tax Advice Using “Purposive Textualism” To Deal With Tax Shelters And Promote Legitimate Tax Advice, Scott A. Schumacher
Articles
The last few years have seen a flurry of activity aimed at the tax shelter industry. Beginning with the “covered opinion” rules of Treasury Circular 230 in 2005, the government has adopted several changes to the standards applicable to tax advice, all in an effort stop abusive tax shelters. Most recently, both Congress (in 2007) and Treasury (in 2008) have revised the standards applicable to tax advice to require that a position have a “more likely than not” chance of succeeding on the merits, or the position must be disclosed to the IRS. While the government’s desire for reform is …
Acquiring Innovation, Xuan-Thao Nguyen, Jeffrey A. Maine
Acquiring Innovation, Xuan-Thao Nguyen, Jeffrey A. Maine
Articles
In recent years, the innovation market has witnessed a new business model involving companies that are mere patent holding shells and not operating entities. They have no customers or products to offer, but they do have an aggressive tactic of using patent portfolios to threaten other operating companies with potential infringement litigation. The strategy is executed with the end goal of extracting handsome settlements. Acquisitions of patents for offensive use have become a major concern to operating companies because such acquisitions pose the threats of patent injunction, interrupting the business and crippling further innovation.
While many operating companies today know …