Corporate Divorce – Preventing and Managing the Break-Up of a Business Partnership
Podcast - Colaborar por contrato... sí funciona
Law School Toolbox Podcast Episode 495: Listen and Learn -- Partnership Liability
The Entrepreneur's Journey with Kass and Mike Lazerow
5 Key Takeaways | Debating Critical Issues Facing the Banking Industry
When a co-shareholder purchases the debt obligations of the company without partners' knowledge
Bar Exam Toolbox Podcast Episode 269: Listen and Learn -- Creation of Partnerships
An Alternative to Consolidations: Key Considerations for Management Services Organizations
Succession Planning to Safeguard Your Law Firm’s Future: On Record PR
Physician Partnership Agreements: Setting Yourself Up for Success
The Current Landscape of Bank-Fintech Partnerships - The Consumer Finance Podcast
Strategic Restructuring for the Future, Putting a Plan Into Action: A Conversation With Gloria Brooks on Building End-of-Life Partnerships
Episode 14 | You Came Up With a Great Business Idea During the Pandemic - Now What?
Into the Future: Modern Partnerships in Health Care Construction Delivery
Episode 12 | Scoring Big for the CLE: A Conversation with David Gilbert, President and CEO of the Greater Cleveland Sports Commission
Episode 11 | Spurring Economic Growth in Northeast Ohio: A Conversation with Bill Koehler of Team NEO
NGE On Demand: Profits Interests: Granting & Receiving with Patty Cain and Josh Klein
PODCAST: Williams Mullen's Trending Now: An IP Podcast - Cause Marketing: Do’s and Don'ts
Navigating the LLC Jungle - I Know a Lawyer Podcast
Sitting with the C-Suite: Managing the Merger and Looking Toward the Future
Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more
Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more
The German Federal Fiscal Court (BFH) confirmed its case law according to which the commercial infection of an upper-tier partnership pursuant to Section 15 para. 3 no. 1 sentence 1 alt. 2 German Income Tax Code...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice...more
On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more
On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more
It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more
Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more
At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more
The “Inflation Reduction Act of 2022” recently announced by Senators Manchin and Shumer to be added to the 2022 Budget Reconciliation bill proposes several significant changes to Section 1061 of the Internal Revenue Code of...more
1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more
“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more
While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more
Living the Dream- “How was your weekend?” Thank you for asking. Awful. “Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress. When the reconciliation budget...more
Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more
The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more