Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more
2/3/2025
/ Capital Gains ,
Debt ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Partnerships ,
Qualified Opportunity Funds ,
Tax Credits ,
Tax Incentives ,
Tax Liability ,
Tax Planning
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
5/2/2024
/ Acquisitions ,
Best Practices ,
Continuing Legal Education ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Corporate Transparency Act ,
Cross-Border ,
Digital Advertising Tax ,
Digital Goods ,
Energy Tax Incentives ,
Events ,
Family Offices ,
Federal Taxes ,
Foreign Assets ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
Income Taxes ,
Internet Tax Freedom Act ,
IRS ,
Mergers ,
Multinationals ,
OECD ,
Passive Foreign Investment Company ,
Pillar 2 ,
Reorganizations ,
Research and Development ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
Virtual Currency
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/19/2021
/ Capital Gains ,
Claim Limitations ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Benefits ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/12/2021
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Deferral ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
10/21/2021
/ Capital Gains ,
FIRPTA ,
Foreign Investment ,
Investment ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Tax Code ,
Tax Liability
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more
The unique needs of ultra-high net worth families, their family office representatives and other advisers are multidimensional and ever-evolving. Join us November 21 for McDermott Will & Emery’s Private Client East Coast...more
10/22/2019
/ Aircraft ,
Aircraft Financing ,
Client Services ,
Confidential Information ,
Estate Planning ,
Events ,
Family Businesses ,
Foreign Investment ,
High Net-Worth ,
Inbound Investments ,
Investment Management ,
Outbound Transactions ,
Tax Audits ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Trust Funds ,
Wealth Management
The Tax Cuts and Jobs Act introduced an important new benefit to US corporations that own 10 percent or more of a foreign corporation. Specifically, a full participation exemption has been enacted that exempts certain foreign...more
6/19/2018
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Dividends ,
Foreign Corporations ,
Foreign Subsidiaries ,
GILTI tax ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform