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Sales of Real Estate Involving Non-U.S. Sellers – FIRPTA Considerations for Both Parties

Transactions involving the disposition of a U.S. real property interest (“USRPI”) by a foreign person (i.e., a nonresident alien individual or foreign entity, the seller) are subject to the Foreign Investment in Real Property...more

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

Qualified Small Business Stock – Overview and Useful Strategies

Founders, entrepreneurs, venture capitalists and other investors (all of which are collectively referred to herein as “investors”) should be familiar with Internal Revenue Code Section 1202, a valuable provision that...more

Internal Revenue Service Warns of “Mills” Taking Advantage of Taxpayers With Offer in Compromise (“OIC”) Program

In a recent news release (available here), the Internal Revenue Service (“IRS”) warned taxpayers about promoters claiming their services are needed to resolve unpaid taxes owed to the IRS....more

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