28 July 2025 Americas Tax Roundup | 28 July 2025 | | A weekly summary of the top weekly tax news, trends and developments in the Americas | | | | | | | | | | This week's tax news from the Americas - Brazilian Supreme Federal Court partially reinstates Government Decree related to changes in IOF
The Brazilian Supreme Federal Court granted an injunction on 17 July 2025, partially reinstating the effects of Decree No. 12,499/2025, which introduced changes to the Tax on Financial Operations (IOF) applicable to credit transactions and foreign exchange transactions. Effective immediately upon publication of the decision, the tax rates will revert to the modified rates pursuant to Decree No. 12,499/2025.
- US Tax Court finds AbbVie properly deducted merger termination fee as an ordinary loss
The US Tax Court, in AbbVie Inc. and Subsidiaries v. Commissioner of Internal Revenue, 164 T.C. No. 10, held that a nearly $1.6 billion merger termination fee (Break Fee) paid by AbbVie to Shire plc is deductible as an ordinary loss, contrary to IRS claims that it should be treated as a capital loss under IRC Section 1234A. The holding emphasizes that the Break Fee was related to services, not property, as it stemmed from AbbVie's board's decision not to recommend the merger.
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Document ID: 2025-1581 |