Insights

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”

Washington – August 17, 2023: The 2024 edition of The Best Lawyers in America® has recognized 47 firm lawyers as "Best Lawyers" and 41 lawyers as “Ones to Watch.”

Tax partner Carina Federico and Tax counsel Eleanor Moran McWaters discuss IRA and Tax Exempt Entities.

The Eighth Circuit partially overturned the district court in Mayo Clinic v. United States, holding that only organizations that have a primary purpose or function that is educational qualify under Section 170(b)(1)(A)(ii). Mayo Clinic v. United States, No. 19-3189, 2021 WL 1916000 (8th Cir. May 13, 2021). However, notably, the court agreed with the district court in part and concluded that Treasury Regulation § 1.170A-9(c)(1) unreasonably limits educational organizations to only those principally providing formal instruction.

The Tax Court recently held that an S corporation, Enercon, could not claim research tax credits that it passed through to its owners because the research qualifying for the credits was completed under a contract with another company and Enercon did not retain substantial rights to the research. Tangel v. Comm’r of Internal Revenue, T.C.M. (RIA) 2021-001.

Crowell & Moring’s Tax Group invites you to join us for the 37th Annual Managing Tax Audits and Appeals. The seminar will provide an overview of everything you need to know about recent developments and hot topics in tax, from planning through litigation, including perspectives from the IRS.