Overview
Lauren Azebu, Eric Solomon, and Art Gertel (principal of MedSciCom LLC) co-authored an article titled "Satisfying the ATB Requirement: Is Income Collection Necessary?" for Tax Notes Federal. The article, published on June 22, analyzes LTR 202009002, the first spinoff ruling on a research and development (R&D) business with no collection of income. Additionally, it examines the R&D process and pre-commercialization income opportunities in the drug industry, considers other possible fact patterns, and speculates on future guidance.