Bernie Pistillo

Bernie Pistillo

Morrison & Foerster LLP

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Recently Proposed Treasury Regulations Regarding the Allocation of Partnership Recourse and Nonrecourse Liabilities Contain...

On January 29, 2014, the Internal Revenue Service (“IRS”) and the Treasury Department issued proposed regulations (the “Proposed Regulations”) modifying the rules under Section 752 regarding the allocation of recourse and...more

2/11/2014 - IRS Partnerships Personal Liability Professional Liability Recourse Proceedings

Managing Offshore Holding Companies from China: Recent Case May Suggest Increased Tax Risk

As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an...more

10/29/2013 - Bank Holding Company China Foreign Investment Offshore Funds

Recent Changes Allow Tax-Free Receipt of up to $10 Million in Gain from the Sale of Small Business Stock

One silver lining to the American Taxpayer Relief Act of 2012 (“ATRA”) is that it extended the 100% exclusion for capital gain on qualified small business stock (“QSBS”) acquired between 2010 and 2011 to include stock...more

1/18/2013 - Alternative Minimum Tax American Taxpayer Relief Act Capital Gains Fiscal Cliff Gain Exclusion Qualified Small Business Stock

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