Impuesto de Timbre: Cuantía indeterminada
5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
Insider Transaction Traps for the Unwary
Essentials for Balancing Taxes and Legal Risk
Business Better Podcast Episode: Bridging Campuses: Legal Insights on Education Industry Consolidation - Real Estate and Tax
Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
5 Key Takeaways | Income Tax Jeopardy! A Potpourri of Hot Topics
REFRESH: Loot and Private Foundation Rules – Part 2
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
Domestic Tax Planning - Podcast with Janathan Allen
Tax Liability Insurance Products: A Hidden Gem in the Transactional Lawyer’s Tool Box
JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become Norm
Podcast: Got Mail? What to Do When the IRS Contacts You [More with McGlinchey, Ep. 42]
The legal landscape for family investment vehicles in Washington shifted dramatically after the Antio LLC v. Department of Revenue decision of the Washington Supreme Court. In Antio the taxpayers were a group of investment...more
In a proceeding for suspension of enforcement, the Federal Fiscal Court (BFH) has concluded that also disproportionate contributions into the capital reserve do not constitute a gift tax-relevant increase in the value of...more
New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more
Although in prior articles in this publication, I addressed tax issues faced by physicians and other practice groups, the purpose of this article is to guide physicians and other medical professionals as they compare the...more
Choosing the right legal structure for a decentralized autonomous organization (DAO) can make or break a web3 project before it deploys. From tax efficiency and governance mechanisms to liability protection and regulatory...more
In the increasingly global world of online business, it’s not unusual for entrepreneurs, freelancers, and consultants to seek a business structure that supports international operations, offers stable banking options, and...more
This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more
La Cour administrative d’appel de Marseille, statuant sur renvoi du Conseil d’État, a estimé que la société ne démontrait ni l’existence de prestations effectives distinctes de celles de son gérant, ni une volonté claire de...more
The purchase of a yacht is a significant financial investment that requires navigation of a multitude of legal issues. Consultation regarding these issues, as well as tax, liability protection and venue location, should all...more
Dans un arrêt du 6 mars 2025, la Cour administrative d'appel de Bordeaux s'est prononcée sur la méthode mathématique d'évaluation de titres de SCI utilisée par l'administration, ainsi que sur la caractérisation d'une...more
Consider the following hypothetical. A corporate client hires a lawyer in connection with purchasing a controlling interest in an LLC. The lawyer structures the deal to lower the client's tax liability based on his assumption...more
This note only addresses subsidiaries of Nordic companies. Branch offices are rarely attractive for foreign companies because they result in direct exposure for the foreign company to liability in the U.S. and jurisdiction by...more
According to the New York City Comptroller, the City collected approximately $1.13 billion in Real Property Transfer Tax (“RPTT”) in the FY 2024. The Comptroller’s Office has forecast that $1.21 billion of RPTT will be...more
Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more
On January 17, 2025, the UK Court of Appeal (Court) released its decision on whether certain members of BlueCrest Capital Management (UK) LLP (BlueCrest) should be taxed as employees under the UK “salaried members” rules (the...more
If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more
Art and collectibles, while beautiful and culturally significant, can pose significant estate planning challenges. At the time of death, these assets are subject to estate taxes based on their fair market value. Without...more
Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more
On 10/22/24, the IRS announced that is has officially commenced operations of the newly established pass-through field operations unit within its Large Business and International (LB&I) division, which was announced last...more
I. General Overview - As of 2020, Mexico has a population of 126,014,024 according to the Mexican National Institute of Statistics and Geography (Instituto Nacional de Estadística y Geografía). Covers a land area of...more
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
NY Needs the Revenue- A couple of weeks ago, the Tax Foundation released its latest “State Business Tax Climate Index,” which assesses a state’s tax system and compares it to that of other states. New York seems to be a...more
In addition to Washington’s real estate excise tax (REET), transferors of ownership interests in entities that own real property in Washington must also factor in Washington’s capital gains tax when making such transfers. ...more
In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more
After almost 20 years, the IRS has again ruled that the conversion under state law of a limited liability company (LLC) disregarded for tax purposes to a corporation did not result in a “significant modification” of the...more