Supreme Court Rocks Patent World

Recently pending before the U.S. Supreme Court was a decision on whether Samsung would owe Apple nearly $400 million in damages. The court’s ruling on that case will alter how much Samsung owes for patent infringement, and change patent law going forward. The ruling clarifies the meaning of “article of manufacture” under section 289 of…

Continue reading

Challenge IRS Fee Waiver Rules

In July 2015, the U.S. Department of the Treasury issued proposed regulations (REG-115452-14) pursuant to IRC 707(a)(2) addressing the tax treatment of certain private equity management fee waivers. Under the proposed regulations, the conversion of a management fee to a capital contribution without any “significant entrepreneurial risk” may be a “disguised payments for services.” Such…

Continue reading