In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more
The COVID-19 pandemic has caused employers to focus on ways they can help employees who have been victims of the disaster....more
Plano Molding Co. (target), a manufacturer of plastics, was acquired by Plano Holding, an affiliate of the Ontario Teachers’ Pension Plan Board (buyer), from Tinicum Capital Partners (seller). ...more
1/15/2020
/ Business Expenses ,
Corporate Sales Transactions ,
Fees ,
Finder's Fees ,
Merger Agreements ,
Purchase Price ,
Safe Harbors ,
Section 162 ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Returns
The treatment of transaction costs in the context of a transaction involving a partnership that is either the acquiring entity or the target entity raises unique issues....more
Recent hurricanes and fires have caused employers to focus on how to help employees who have been victims of disasters. Employees also suffer hardships that are not related to disasters, but that result from personal...more
IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN.
What happens when settling parties agree that the defendant will...more
In an important recent decision, United States v. Quality Stores, Inc., et al., Case No. 01-1563, 2012 U.S. App. LEXIS 18820 (6th Cir. Sept. 7, 2012), the U.S. Court of Appeals for the Sixth Circuit held that supplemental...more