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The Earnout Equation: Tax Tips for Both Buyers and Sellers

Earnouts are a form of contingent consideration that the buyer of a business pays to the seller in the period following the acquisition, based on the business achieving various financial metrics related to its performance...more

The Tax Implications of Divorce: Alimony, Child Support, IRAs and More

Divorce is a complex and emotionally charged process that also brings substantial financial considerations, with three of the most significant financial aspects of a divorce being alimony (spousal support), child support, and...more

Maximizing Value: The Art of Purchase Price Allocation in Real Estate Deals

When a business is sold, the most important overall aspect of negotiations between a cautious buyer and determined seller may be due to the agreed-upon purchase price for the business. However, when the buyer is purchasing...more

IRS Targeting Partnership Basis-Shifting Transaction Schemes

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

The Brass Tacks: IRS Creates Process for Withdrawing ERC Claims

The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims. This surely will come as a relief to taxpayers who...more

IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm

In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more

Key Questions When Determining Eligibility for State Historic Tax Credits

Real estate developers have long had ample reasons to take on projects involving historic buildings, courtesy of Section 47 of the Internal Revenue Code of 1986. As amended, Section 47 (the “Code”) provides for a...more

How IRS Is Cracking Down on Employee Retention Tax Credit Fraud

The Internal Revenue Service (“IRS”) has recently devoted great attention to detecting, investigating, and prosecuting fraud, particularly as it relates to the Employee Retention Tax Credit (“ERC”) post-COVID. On a webinar...more

Do It Better Than ‘Succession’: How to Optimize Transition for Your Waystar Royco

Over the past three seasons, fans of the hit HBO series Succession have had an entrée into the fabulous lifestyles enjoyed by members of the Roy family and a front-row seat from which to observe the myriad succession...more

Trust Me. You Need a Trust.

So, you finally sat down to start your estate plan but have heard so many conflicting points about wills and trusts that you don’t know where to start. If you are choosing between a trust and a will, you’re not alone. One of...more

Here Comes the Sun: The Inflation Reduction Act Provides a Multitude of New Tax Incentive Opportunities for the Solar Industry

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (“IRA” or the “Act”) into law. The IRA, which contains several energy-related tax credits and extends and modifies some existing credits in the...more

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