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Tax Planning › Disregarded Entities › Income Taxes

Pillsbury Winthrop Shaw Pittman LLP

Vindication: The U.S. Tax Court Sustains IRS Position on Basket Options in GWA, LLC

Pillsbury Winthrop Shaw Pittman LLP on

In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

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More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Freeman Law

[Webinar] Preparing Form 5472 step by step instructions - February 22nd, 12:00 pm - 2:00 pm CT

Freeman Law on

You are invited to Freeman Law Tax Academy Series - FORM 5472: STEP BY STEP INSTRUCTIONS - Learning Objectives: - Determine the applicability of Form 5472 - Properly complete Form 5472 - Identify prospective...more

Foodman CPAs & Advisors

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Foodman CPAs & Advisors on

Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

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