Preload of Generic Software Precludes Finding of Substantial Transformation in U.S. When Replaced with Proprietary Software That Enhanced Functionality
Client Alert | less than 1 min read | 05.31.16
Customs and Border Protection has released its final determination concerning different versions of certain network transceivers and high speed cabling devices that require software to be functional. CBP concluded that “blank” network transceivers imported into the U.S. where proprietary software was first downloaded were substantially transformed in the U.S., whereas network transceivers already programmed with generic software when imported were not substantially transformed by subsequent replacement of the generic software with proprietary software that enhanced and broadened functionality allowing interoperability with different OEM systems.
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Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine
Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below.
Client Alert | 2 min read | 07.13.26
Department of War Immediately Suspends CMMC Phase II Requirements, Launches 60-Day Reform Review
Client Alert | 3 min read | 07.10.26
Client Alert | 5 min read | 07.10.26

