Ordinary and necessary

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Corporate Rate Increase? 

We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan”[i]) following a marathon session during which Senate Democrats tried to address the concerns of centrists within their own party,[ii] but without alienating more progressive members of…

Transaction Costs

It is a basic principle of M&A taxation that the more a seller pays in taxes on the sale of its business, the lower will be the economic gain realized on the sale; similarly, the more slowly that a buyer recovers the costs incurred in acquiring a business, the lower will be the…