Deal volume across the healthcare industry generally appears to have steadied despite headwinds. The general sentiment is that buyers have adapted to the current interest rates and are gritting their teeth and pressing...more
Taxpayers have long attempted to limit the application of the Self-Employment Contributions Act (SECA ) taxes to income that is akin to employment income and not investment, or passive income, by relying on Code §1402(a)(13)....more
The BBS Connect Newsletter is an extension of our BBS Connect Operating Partner Database, which connects middle-market healthcare-focused private equity funds with experienced executives. Each installment will introduce you...more
OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more
As we previously reported, the Multistate Tax Commission has undertaken an ambitious project on the state taxation of partnerships. Their partnership work group consists of volunteers from numerous state revenue departments,...more
Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more
One of the biggest mistakes a cannabis and hemp business owner can make is trying to do everything alone. To ensure this mistake is avoided, business owners should first develop the right internal team, and then look to...more
Dramatic market shifts are causing family offices to reconsider their structures, especially family office compensation arrangements that are based on public market valuations. These same dynamics are creating opportunities...more
Large-scale solar development is big business, and solar EPC Contracts are big business by association. In Q2 2017, the U.S. solar market installed 2,387 MWdc, an 8% increase year-over-year, and the largest second quarter...more
Earlier this year, HM Revenue & Customs published various ideas to ‘clarify’ the tax treatment of partners in partnerships, as part of its response to a consultation on changes to the taxation of UK partnerships. Draft...more
Careful Evaluation and Planning Should Be Undertaken When the Partnership Is Formed and When Assets Are Contributed to Evaluate the Potential Impact of Section 721(b). Many taxpayers choose partnership structures...more
In the inaugural column of ‘‘Power and Taxes,’’ we discussed the tensions surrounding the requirement that an investor be an owner when a project is placed in service in order to qualify for the investment tax credit under...more
Although this blog is focused typically on opportunities for institutional investors to recover losses as class members or plaintiffs, we think this decision in Youngers v. Virtus Investment Partners, Inc., may also be of...more
I. OVERVIEW - A recently released legal memorandum by the Internal Revenue Service (IRS) Office of Chief Counsel, CCA 201606027 (the “Memorandum”), concluded that a so-called “bad boy guarantee” provided by a sponsor of...more
If you thought it was difficult to make a federal securities fraud claim stick in the Fourth Circuit, the court has now raised the bar even higher. The Fourth Circuit recently affirmed a trial court’s dismissal of securities...more
Companies that carry out qualifying investment projects in the Russian Far East enjoy tax benefits under a new Federal Law “On the Introduction of Amendments to Parts One and Two of the Tax Code of the Russian Federation...more