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Shareholders › Tax Deferral › Income Taxes

Barnea Jaffa Lande & Co.

Knesset Committee Approves Bill Easing Tax Relief in Restructuring

Barnea Jaffa Lande & Co. on

The Knesset Finance Committee approved a draft bill for second and third readings to ease the conditions for tax relief during corporate restructuring. The bill was first published in the initial draft bill within the tax...more

Barnea Jaffa Lande & Co.

Phantom Stock: A Strategic Tool for Equity Incentivization

Barnea Jaffa Lande & Co. on

In the contemporary landscape of talent management, organizations face major challenges in recruiting and retaining top-tier professionals. Equity incentive mechanisms have emerged as a sophisticated strategy to cultivate...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

Farrell Fritz, P.C.

The Federal Anti-Deferral Rules For Foreign Income –Just A Reminder, There’s No Easy Way Out

Farrell Fritz, P.C. on

It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more

Farrell Fritz, P.C.

One Corporation, One Property, Two Shareholders – Can They Be Separated? Without Tax?

Farrell Fritz, P.C. on

A Basic Principle- Do you remember the scene from “History of the World Part I” when Mel Brooks, in the role of Moses, calls out “Hear me, oh hear me! All pay heed! The Lord, the Lord Jehovah has given unto you these...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

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