News & Analysis as of

Tax Planning

Lowenstein Sandler LLP

Section 280G Unpacked: Pitfalls and Planning for Tech Startups

In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein’s Emerging Companies & Venture Capital practice group, about the complexities and challenges of...more

Mintz - Intellectual Property Viewpoints

Should Your Company Use an IP Holding Company? Here’s What You Need to Know

When it comes to intellectual property (IP), where your company holds its assets can be just as important as what you own. Many companies default to keeping IP within their operating entities… but is that the smartest move?...more

Adler Pollock & Sheehan P.C.

Understanding the Ins and Outs of an FLP

A family limited partnership (FLP) is an estate planning tool with various benefits. These include centralized management of family assets, the ability to transfer wealth without ceding control, reduced gift and estate taxes,...more

Opportune LLP

Tax Planning Transformed: A Look at 20 Years of Evolution

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For many years, taxes were the quiet endnote in financial decisions, an obligatory step taken after the strategic direction had been set. In mergers and acquisitions, IPO planning, and corporate restructurings, tax...more

Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for Investment Funds and Sponsors

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On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Venable LLP

International Tax Reform Under the "One Big Beautiful Bill": What Global Businesses Need to Know

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As the U.S. Senate is set to consider President Trump's domestic policy bill, non-U.S.-based multinational businesses and non-U.S. investors are preparing for wholesale changes to the U.S. international tax landscape,...more

Sullivan & Worcester

Remediation of M&A REIT Targets (UPDATED)

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The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of...more

Hone Maxwell

Why Some International Entrepreneurs Use U.S. LLCs Without Paying U.S. Tax

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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

Whiteford

Client Alert: Inside the One Big Beautiful Bill Crucial Tax Updates for Individuals, Business Owners, and Nonprofits

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On May 22, 2025, the House of Representatives passed H.R. 1-119th Congress (2025-2026), titled as the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses soon to sunset provisions of...more

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more

Walkers

Thinking ahead: Key considerations for winding up Guernsey investment funds

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The process of winding up a Guernsey fund involves several important considerations that boards, fund managers, investment advisers and administrators must navigate carefully. This article explores six aspects which we...more

Kohrman Jackson & Krantz LLP

Navigating Interest Income in 1031 Exchanges: Strategic Considerations for Tax Deferral

As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more

Wilson Sonsini Goodrich & Rosati

Key UK Tax Implications of the Delaware Flip

U.S. venture capitalists investing at the early stages (Seed and Series A) in a UK (or other non-U.S.) company often require that the company “flips” its corporate structure and establishes a U.S. (most commonly Delaware)...more

Mandelbaum Barrett PC

The High Cost of Delay: Why Ultra-High-Net-Worth Families Must Act Now on Estate and Asset Protection

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For ultra-high-net-worth individuals (UHNWIs) whose estates far exceed the 2025 federal lifetime exemption of $13.99 million per person, the stakes for estate and asset protection planning have never been higher-or more...more

Mandelbaum Barrett PC

Special Needs Planning 101: 10 Ways to Safeguard Your Loved One’s Future

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Careful planning for a loved one with disabilities is one of the most important and compassionate acts you can take as a parent or caregiver. It’s not just about securing their financial future, it’s about preserving their...more

McDermott Will & Emery

The Proposed US Tax Regime for Non-US Investors and Companies

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On May 22, 2025, the US House of Representatives narrowly passed a sweeping $3.8 trillion tax reconciliation package known as the One Big Beautiful Bill Act. The legislation now moves to the US Senate, where significant...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Katten Muchin Rosenman LLP

Evolving Estate Planning for Family Business Owners: Adapting to Life Stages and Growth

On April 30, 2025, Katten hosted Loyola University Chicago's Family Business Center for the "Family Business Through a Legal Lens" program. Private Wealth Partner Adam Damerow and Loyola University Chicago School of Law...more

Allen Barron, Inc.

Tax Developments for US Expatriates

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There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more

Cadwalader, Wickersham & Taft LLP

Treasury Official Indicates New Taxpayer Friendly Spin-Off Regulations are Coming—But No Change in Ruling Policy in the Meantime

At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more

Cadwalader, Wickersham & Taft LLP

Nordcurrent: Interpreting Anti-Abuse Rules

On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more

Allen Barron, Inc.

Tax and Legal Advice When Selling Your Business

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What do you need to know if you intend to sell your business? It is essential to have integrated tax and legal advice when selling your business to ensure maximum net profit and minimize contingent liability. Look for a...more

Rivkin Radler LLP

Terminating a Trust? Don’t Forget to Consider This Tax Issue

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Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more

McCarter & English, LLP

Tax Planning for Sports Franchise Owners, and the Rest of Us

Jim Irsay, the longtime owner and CEO of the Indianapolis Colts, died unexpectedly in May 2025. Irsay leaves behind not only a legacy in the NFL but also a sports franchise valued at approximately $4.4 billion. As Irsay’s...more

Proskauer - Employee Benefits & Executive...

Executive Use of Corporate Aircraft: Navigating Tax, SEC Disclosure and Other Key Considerations

Companies are increasingly allowing their chief executive officers and, in certain circumstances, other executives to use corporate jets (which may be chartered flights or fractionally or fully owned aircraft) for personal...more

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