News & Analysis as of

Subsidiaries S-Corporation Internal Revenue Code (IRC)

Holland & Knight LLP

Converting from an S Corporation to Qualified Small Business Stock

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The One Big Beautiful Bill Act (OBBB) has spurred even more interest among businesses that may qualify for the tax benefits associated with qualified small business stock (QSBS), including businesses that currently are...more

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

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Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

Venable LLP

Seller Beware - Court Rules That California Can Tax Gain from the Sale of Goodwill

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A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more

Williams Mullen

ESOP Essentials: Can My Company Offer An ESOP? Selected Tax Guidance on Choice of Entity, Business Structure and ESOPs

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An employee stock ownership plan (ESOP) is a type of tax-qualified retirement plan. ESOPs are designed to invest primarily in qualifying employer securities, as defined in applicable tax rules....more

Herbert Smith Freehills Kramer

Flow-through Tax Status as a Property Right? The Case of Schroeder Brothers Farms

A recent case from the Western District of Wisconsin, In re Schroeder Brothers Farms of Camp Douglas LLP, may raise a new issue for the bankruptcy treatment of tax attributes in flow-through entities. The court in Schroeder...more

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