Once Removed Episode 21: Passing Down the “Family Cottage” or Other Legacy Property
Business Succession Planning Podcast with Janathan Allen
M&As – Novation and Recertification
Preserving Deferred Tax Assets in a Capital Raise
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
La "Ley de reducción de impuestos y empleos" (la "Ley") contiene una provisión que es una "acompañante hermana" de la Deducción por Dividendos Recibidos (DRD) que implica ventas o transferencias que envuelven un 10% de la ...more
The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign...more
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more
Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more
On Sept. 14, 2015, the IRS released proposed regulations that would significantly alter the treatment of outbound transfers of foreign goodwill and going concern value by a U.S. person to a foreign corporation. Under the...more
On September 14, 2015, the IRS released proposed regulations (the “Proposed Regulations”) that would significantly alter the treatment of outbound transfers of foreign goodwill and going concern value by a U.S. person to a...more
Monday, the IRS and Treasury released proposed regulations governing the treatment of certain transfers of foreign goodwill and going concern value. When a U.S. person contributes property to a foreign corporation,...more
In This Issue: - IRS Clarifies Deadline for Correcting Withholding Documentation - Consent Payment Modifying Contingent Payment Debt Instrument Must be Tested for Significance - IRS Concludes Correction of Error...more
On September 22, 2014, the United States Department of the Treasury and the Internal Revenue Service issued a Notice (Notice 2014-52) that limit "inversion" transactions and their potential tax benefits. In general, an...more
In a corporate inversion, a U.S. corporation (typically the parent of an affiliated group) becomes a wholly owned subsidiary of a foreign corporation (through a merger into the foreign corporation’s U.S. subsidiary) or...more