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Client Alert

IRS Extends Feedback Period on Form 6765, Delays Section G Requirement

By: Maxwell A. Shapiro and Candice G. Long

On October 1, 2025, the Internal Revenue Service issued IR-2025-99, providing important updates on the ongoing rollout of the revised Form 6765, Credit for Increasing Research Activities, commonly referred to as the R&D Tax Credit. The announcement extends the comment period for the draft instructions, delays the requirement to complete Section G and lengthens the ...

Client Alert

Sweeping Budgetary and Tax Legislation Enacted, Impacting All Sectors

On July 3, 2025, the U.S. House of Representatives passed H.R.1, referred to as the “One Big Beautiful Bill Act” (“OBBBA”). The following day, President Trump signed the bill into law, marking a key milestone in his second-term agenda. OBBBA introduces sweeping changes to numerous areas of U.S. federal income tax law in addition to ...

Event

ABA Section of Taxation 2025 May Tax Meeting

Winthrop & Weinstine will be attending the American Bar Association’s (ABA) Section of Taxation. This is the premier event for lawyers interested in all aspects of tax law.  Join us in Washington, DC to learn from and meet with the country’s leading tax lawyers and government officials, discussing the latest federal, state, and local tax policies ...

Quoted

Breaking the Ice: Attorneys team again to lead tax practice

Rafi Mottahedeh and Joel Peters-Fransen, former Big Law tax lawyers, in-house counsel and colleagues, are working together again as shareholders and co-chairs of Winthrop & Weinstine’s national tax practice. The pair intend to expand the depth and breadth of the Minneapolis firm’s tax practice, which has 20-plus lawyers. “It’s less about us individually and more ...

Event

Lessons Learned from the Cross Refined Coal Case

Rafi Mottahedeh will be a moderator at the American Bar Association Section of Taxation’s Midyear Tax Meeting on January 18, 2024. The title of the session is, “Lessons Learned from the Cross Refined Coal Case.” For more information, please see the event website.

January 18, 2024

Event

Recent Inbound Tax Cases & Other Guidance

Rafi Mottahedeh will be a moderator at the American Bar Association Section of Taxation’s Midyear Tax Meeting on January 18, 2024. The title of the session is, “Recent Inbound Tax Cases & Other Guidance.” For more information, please see the event website.

January 18, 2024

Event

What Profits? Gross Income Allocations for Carried Interest/Performance Allocations in Private Funds

Rafi Mottahedeh and Joe Peters-Fransen are panelists at the American Bar Association Section of Taxation’s Tax Meeting on May 4, 2023. The title of his panel is, “What Profits? Gross Income Allocations for Carried Interest/Performance Allocations in Private Funds.” For more information, please see the event website.

May 4, 2023

Movin’ on Up: Is indexing basis for inflation worth a fresh look?

Rafi Mottahedeh will be a panelist at the American Bar Association Section of Taxation’s Tax Meeting on May 4, 2023. The title of his presentation is, “Movin’ on Up: Is Indexing Basis for Inflation Worth a Fresh Look?”

Event

U.S. Shareholder Basis in Foreign Corporations Post-Tax Reform

Rafi Mottahedeh will be a panelist at the American Bar Association Section of Taxation 2019 Midyear Tax Meeting. The title of the panel is, “U.S. Shareholder Basis in Foreign Corporations Post-Tax Reform.”  

May 2, 2019

Article

The Import Price Advantage Under the Border-Adjusted Tax

Rafi Mottahedeh is the co-author of the article, “The Import Price Advantage Under the Border-Adjusted Tax.”  The blueprint proposes a cash-flow-based border-adjustable tax (BAT) that combines elements of a consumption tax and an income tax. Download the article here.

Article

Liquidations that Run for the Border

Rafi Mottahedeh is author of, “Liquidations that Run for the Border,” for the M&A Tax Report.

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