News & Analysis as of

Income Taxes › Employee Stock Ownership Plans

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Blank Rome LLP

Cannabis ESOPs Provide Solutions for Operators

Blank Rome LLP on

As we enter Q2 of 2025, the cannabis industry has become increasingly pessimistic about the elimination of Section 280E of the Internal Revenue Code, whether via rescheduling or otherwise. Rescheduling appears unlikely in the...more

Orrick, Herrington & Sutcliffe LLP

Legal Ninja Snapshot: #ESOP & Flips - U.S. ESOPs for Employees of the German Subsidiary Now Available

Orrick, Herrington & Sutcliffe LLP on

Good news! The second chamber (Bundesrat) has now paved the way for the eagerly awaited and much-debated inclusion of a group privilege in sec. 19a of the German Income Tax Act (“EStG”). German start-ups that have done the...more

Orrick, Herrington & Sutcliffe LLP

Legal Ninja Snapshot: #ESOP & Flips — U.S. ESOPs May Become Available for the Employees of the German Subsidiary

Orrick, Herrington & Sutcliffe LLP on

Much has been written about the unsatisfactory tax situation of German employees when it comes to equity-based employee stock (option) programs ("ESOP"). Historically, employees were taxed at the time of issuance of shares...more

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

Mayer Brown on

Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Orrick, Herrington & Sutcliffe LLP

Zukunftsfinanzierungsgesetz und ESOPs – Wirklich der große Wurf?

Orrick, Herrington & Sutcliffe LLP on

Wichtiger Hinweis: Die folgenden (rechtlichen) Ausführungen dienen nur der allgemeinen Information, sind nicht abschließend und stellen keine rechtliche, steuerrechtliche oder sonstige Beratung dar. ...more

McDermott Will & Schulte

Weekly IRS Roundup August 7 – August 11, 2023

McDermott Will & Schulte on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 7, 2023 – August 11, 2023....more

Gerald Nowotny - Law Office of Gerald R....

(A)ESOP's Fables - The Income and Estate Tax-Free ESOP

Gerald Nowotny - Law Office of Gerald R.... on

ESOPs are a great tool for the business owner and employees. The planning technique complimenting the ESOP dramatically enhance the benefits for the Seller making the Seller more willing to enter into the ESOP arrangement....more

Freeman Law

Tax Court in Brief - February 2022

Freeman Law on

The Tax Court’s recent decision in Larson v. Commissioner involved a frequent tax issue in the context of S corporations and control persons: Whether restricted stock of an S-corporation contributed to an employee stock...more

Freeman Law

Tax Court in Brief January 31 – February 4, 2022

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Levenfeld Pearlstein, LLC

New Legislation Benefiting 100% ESOP-Owned Defense Contractors

Levenfeld Pearlstein, LLC on

For over 20 years, Congress has provided powerful incentives for S corporations to sponsor employee stock ownership plans (“ESOPs”) through the tax code provisions that exempt all of the income of a 100% ESOP-owned S...more

Troutman Pepper Locke

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

Troutman Pepper Locke on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Farrell Fritz, P.C.

Deducting Payments Between Related Parties

Farrell Fritz, P.C. on

Potential for Abuse- Many years ago, Congress decided that taxpayers who were “related” to one another should be required to use the same accounting method with respect to transactions between them in order to prevent the...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 4

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ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 3

Morrison & Foerster LLP on

ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

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