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Internal Revenue Service Sellers

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DarrowEverett LLP

The Earnout Equation: Tax Tips for Both Buyers and Sellers

DarrowEverett LLP on

Earnouts are a form of contingent consideration that the buyer of a business pays to the seller in the period following the acquisition, based on the business achieving various financial metrics related to its performance...more

DarrowEverett LLP

Unlocking Tax-Free Gains: The Power of QSBS in Mergers & Acquisitions

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Internal Revenue Code (IRC) Section 1202 offers a significant tax incentive for investors in qualified small business stock (QSBS). This provision allows eligible shareholders to exclude up to 100% of capital gains realized...more

Mintz - Tax Viewpoints

F-Reorgs: How Buyers’ and Sellers’ Favorite ‘F Word’ Optimizes M&A and Private Equity Transactions Involving S Corporations

Mintz - Tax Viewpoints on

In M&A and private equity transactions, buyers and sellers are consistently looking for ways to maximize value, which requires a critical focus on structuring the transaction in a tax-efficient manner. This pursuit of tax...more

DarrowEverett LLP

Maximizing Value: The Art of Purchase Price Allocation in Real Estate Deals

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When a business is sold, the most important overall aspect of negotiations between a cautious buyer and determined seller may be due to the agreed-upon purchase price for the business. However, when the buyer is purchasing...more

Clark Hill PLC

[Webinar] Preparing for Clean Energy Tax Credit Transfer Transactions - May 1st, 12:00 pm - 1:00 pm EDT

Clark Hill PLC on

Project developers in the EV, solar, wind, battery, CCUS, hydrogen, biofuels, and energy efficiency markets have been blessed by the IRS with the ability to transfer tax credits directly to willing buyers. Tax equity...more

McDermott Will & Schulte

Weekly IRS Roundup March 11 – March 15, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 11, 2024 – March 15, 2024. ...more

Venable LLP

Earnouts and Their Tax Treatment

Venable LLP on

As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

The Wagner Law Group

Merger and Acquisition Considerations for Employee Benefit Plans

The Wagner Law Group on

In the context of mergers and acquisitions, an acquisition target’s qualified retirement plans, health plans, executive compensation arrangements, and benefit programs (referred to collectively as “benefit programs”) can all...more

McDermott Will & Schulte

Weekly IRS Roundup January 1 – January 5, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 1, 2024 – January 5, 2024. ...more

DarrowEverett LLP

1031 Exchanges and the Complexities of Seller Financing

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With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s...more

McDermott Will & Schulte

IRS Releases Memorandum on Deducting Cryptocurrency Losses

On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more

McDermott Will & Schulte

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Holland & Knight LLP

John Hoover Testifies for NBAA at IRS Hearing on Bonus Depreciation Regulations

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The Internal Revenue Service (IRS) held a hearing on Nov. 28, 2018, regarding its proposed bonus depreciation regulations. Holland & Knight Partner John Hoover testified on behalf of the National Business Aviation Association...more

Cooley LLP

Blog: New 10% Withholding Imposed on Buyers of US Partnership Interests From Foreign Sellers

Cooley LLP on

Be aware that part of the new tax law that came into effect January 1, 2018 imposes upon buyers of interests in U.S. entities taxed as partnerships (whether partnerships, LLCs, etc.) a new withholding requirement, under which...more

Lowndes

Tax Considerations in Real Estate Dispositions

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In a typical real estate transaction, the seller deeds the real property to the buyer. This transaction is simple and straightforward for both buyer and seller. Although it is simple, is it the best structure from a tax...more

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