Foley Partner and Chair of the Emerging Technologies Industry Team, Susan Pravda, led panelists Rob Adler of WordStream, Mohamad Ali of IBM Software Group, and Dennis Rourke of America’s Growth Capital in a discussion on the state of the market today, how to be the best buyer or seller in today’s economy, target valuations, and changes in transaction terms such as earn-outs and purchase price adjustments.
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January 13, 2026
Foley Viewpoints
Recent IRS Guidance on Branch Profits Tax Treaty Benefits for Foreign Reverse Hybrid Entities
The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) (the CCA) that provides helpful guidance regarding the application of the branch profits tax (BPT) in connection with reverse foreign hybrid (RFH) entities and U.S. income tax treaties with foreign countries.
January 13, 2026
Foley Career Perspectives
Foley Attorneys Deepen Boys & Girls Clubs of America Partnership
As the first and only law firm to partner with BGCA on a national scale, Foley supports the organization's youth leadership development strategy through programs and initiatives that open doors for the next generation to thrive.
January 12, 2026
Energy Current
Ninth Circuit Hears Oral Argument in Challenge to California Climate Disclosure Laws SB 261 and SB 253; No Ruling Yet
On January 9, 2026, a three-judge panel for the U.S. Court of Appeals for the Ninth Circuit heard oral argument in a challenge to…