With Ultramercial Remand, Is the Supreme Court Telegraphing View on Patent Eligibility to Federal Circuit?

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.

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.

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…