Recent law changes can provide portfolio company liquidity and/or require reconsideration of 2018–2020 deals. During this webinar, Steven D. Bortnick and Todd B. Reinstein, partners in the Tax and Estates Practice Group of...more
6/26/2020
/ Acquisitions ,
Alternative Minimum Tax ,
CARES Act ,
Carryback Rules ,
Income Taxes ,
Mergers ,
Net Operating Losses ,
Portfolio Companies ,
Private Equity ,
Separation Agreement ,
Tax Credits ,
Tax Planning
If goodwill is personal to a shareholder of a C corporation (or an S corporation with built-in gain), in the context of a sale of the corporation’s assets to a buyer, the shareholder may be able to sell the goodwill...more
At this point, private equity firms are very conscious that debt of their U.S. acquisition vehicles or portfolio companies cannot be guaranteed by controlled foreign corporations (CFCs), nor can more than 65 percent of the...more
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
3/19/2018
/ Capital Gains ,
Foreign Investment ,
Income Taxes ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Withholding Tax