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Convergence Forum for Leaders in Healthcare Innovation

11 May 2023

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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…