Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more
Our Tax Group reviews how the U.S. Supreme Court’s ruling in Loper Bright that overturned many decades of the Chevron doctrine will affect federal and state taxes....more
Our Tax Group sheds light on recent IRS rulings that disallow deductions involving success-based fees in M&A transactions. Contrary to common practice, the IRS recently ruled target companies could not deduct success-based...more
Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.”...more
Our Federal Tax Group digs into IRS Notice 2023-2 guidance on when SPAC redemptions of stock are subject to the new 1% excise tax....more
Our Federal Tax Group finds the sweet spot for corporate inversions. If a U.S. corporation’s shareholders obtain between 50% and 60% of the stock, the exchange could be taxable....more
Our Federal Tax Group sheds light on the tax consequences of a common merger and acquisition (M&A) transaction for both selling and retaining an interest in a business. Proactive tax planning is the best way to ensure...more
Our Federal Tax Group discusses a common but critical partnership operating agreement provision that ensures partners won’t be paying taxes out of their own pockets....more
Our Federal Tax Group discusses straightforward solutions to scenarios that may apply when a family-owned business is structured as a C corporation for tax purposes....more
Our Federal Tax Group highlights a rule that exempts certain small business stock sales from taxes. What kinds of small companies are ideal candidates for qualified small business stock (QSBS) gain exclusions?...more
Beware of being shortsighted. Our Federal Tax Group takes the long view for borrowers and their creditors seeking to use short sales to extricate themselves from nonrecourse debt....more
Our Federal Tax Group examines an IRS letter ruling on a company’s ability to take advantage of Section 197 intangibles. What is a liability limitation fund, and how can a company receive payments?...more
With taxes, the present can affect the past. Our Federal Tax Group takes note of a little-known rule that could allow disaster losses from 2020’s COVID-19 pandemic to be used as losses for 2019....more
Our Federal Tax Group considers the unclear tax powers of the bankruptcy courts and how the IRS won’t take any determinations too kindly....more
What if? As massive as the CARES Act is, there was one tax section that was left out of the final version. Our Federal Tax Group excavates this missing piece and investigates how it would have restored what was repealed by...more
It isn’t just the Federal Election Commission political action committees (PACs) need to worry about. Our Federal Tax Group examines the tax pitfalls for tax-exempt organizations and one worrisome IRS ruling in particular....more
For every upside, there’s a downside, even for bonus depreciation. Our Federal Tax Group considers unexpected avenues to explore under proposed regulations....more
Our Federal Tax Group explores how a foreign person’s books can become relevant for U.S. tax purposes even when it has no contact with the U.S. tax system....more
Executive Summary-
A Supreme Court decision on state taxation of an Indian tribe turned on what a tax is “on.” Our Federal Tax Group parses the meaning of what is actually being taxed and the broader implications for...more
7/1/2019
/ Fuel Tax ,
Highways ,
Imports ,
Preemption ,
Reaffirmation ,
Right to Travel ,
SCOTUS ,
State Taxes ,
Tax Exempt ,
Treaties ,
Tribal Lands ,
WA Supreme Court ,
Washington State Department of Licensing v Cougar Den Inc
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
Our Federal Tax Group examines the signature difference brought about by tax reform’s opportunity zone regime.
Comparison to empowerment zones and enterprise communities -
How the new regime is being used.
How seriously...more
In long-awaited guidance on Section 163(j) post-tax reform, the Treasury and IRS present taxpayers with an expansive definition of “interest,” subjective anti-abuse rules, complex computational instructions, and several...more
Our Federal Tax Group gives a glimpse into the brave new world of selling foreign assets and stock in the wake of the Tax Cuts and Jobs Act.
- Selling a U.S. sub versus selling a CFC
- GILTI as a new option over Subpart...more
Treasury has proposed regulations on Section 951A, the global intangible low-taxed income (GILTI) regime, as well as related regulations for consolidated groups. As expected, the GILTI regime will operate on a consolidated...more
Cash is king in this year’s M&A deals. Our Federal Tax Group investigates the tax implications behind these all-cash deals and what dangers may lie ahead.
- Few stocks are held by taxable persons
- First-step mergers
- A...more