Life sciences companies (particularly early stage companies) may be attracted to an LLC holding company structure as an alternative to a typical C corporation structure to maximize both the purchase price paid by a future...more
8/4/2025
/ Acquisitions ,
Business Entities ,
C-Corporation ,
Choice of Entity ,
Holding Companies ,
Investors ,
Life Sciences ,
Limited Liability Company (LLC) ,
Pass-Through Entities ,
Selling a Business ,
Tax Planning ,
Venture Capital
On July 4, 2025, the President signed into law the “One Big Beautiful Bill Act” (the “Act”).
Among other things, the Act makes permanent many provisions of the 2017 Tax Cuts and Jobs Act (the “TCJA”) that otherwise would...more
7/15/2025
/ Business Taxes ,
Corporate Taxes ,
Excise Tax ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Legislation ,
Tax Rates ,
Tax Reform
On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more
6/3/2025
/ Appeals ,
Fund Managers ,
Income Taxes ,
Investment Funds ,
IRS ,
Limited Partnerships ,
Partnerships ,
Private Equity Funds ,
Self-Employment Tax ,
Tax Court ,
Tax Liability
On April 9, 2020, the Federal Reserve announced actions to implement the Main Street Lending Program authorized under Section 13(3) of the Federal Reserve Act. The program consists of two credit facilities aimed at small and...more
4/15/2020
/ CARES Act ,
Comment Period ,
Coronavirus/COVID-19 ,
Credit Facilities ,
Federal Reserve ,
Financial Stimulus ,
Main Street Lending Programs ,
Relief Measures ,
Special Purpose Vehicles ,
Term Sheets ,
U.S. Treasury
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) and the Families First Coronavirus Response Act (“FFCRA”) provide eligible employers with refundable payroll tax credits for certain wages paid to...more
A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more
Summary: The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code...more