Earl Mellott

Earl Mellott

Foley Hoag LLP

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Latest Publications


A "PATH" to Substantial Tax Savings: Qualified Small Business Stock

In the early 1990s, Congress enacted the qualified small business stock (“QSBS”) rules to incentivize equity investments in certain corporations. The QSBS rules reduce the effective federal income tax rate on the gain...more

6/10/2016 - C-Corporation Capital Gains Corporate Conversions Equity Investors Income Taxes Limited Liability Company (LLC) Protecting Americans from Tax Hikes (PATH) Act Qualified Small Business Stock S-Corporation Stock Repurchases

Partnership Audit Regime Shakeup

The recent Bipartisan Budget Act of 2015 (the “Act”) sets forth a new tax audit regime for partnerships (and limited liability companies taxed as partnerships) that will have far-reaching consequences. The new audit...more

2/5/2016 - Audits Bipartisan Budget IRS Limited Liability Company (LLC) Opt-Outs Partnership Agreements Partnerships TEFRA

Changes on the Horizon? IRS Announces New Plans to Recharacterize Management Fee Waiver Arrangements

On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more

7/31/2015 - Capital Gains Clawbacks Deferred Compensation Fee Waivers Fund Sponsors Internal Revenue Code (IRC) IRS Management Fees Partnership Agreements Partnerships Profits Interests Significant Entrepreneurial Risk (SER)

New Proposals to Tax Carried Interest as Ordinary Income Garner Bipartisan Support

On March 4, 2014, President Obama issued his Administration’s Fiscal Year 2015 Budget, which includes a proposal to tax carried interests (also known as “performance allocations” or “incentive allocations”) in investment...more

3/7/2014 - Corporate Taxes Hedge Funds Incentives Income Taxes Performance Incentives Tax Reform

100 Percent Tax Exemption for Gain on Certain Qualified Small Business Stock Expiring at Year End

In January 2013, Congress enacted legislation that could provide certain investors who acquire qualified small business stock (“QSBS”) before the end of 2013 with a significant tax benefit. In effect, the gains realized from...more

12/13/2013 - Alternative Minimum Tax Income Taxes Investors Qualified Small Business Stock Tax Exemptions Year-End Planning Year-End Tax Planning

Massachusetts "Tech Tax" Repealed

On September 27, 2013, Massachusetts Governor Deval Patrick signed legislation to retroactively repeal the recent extension of the 6.25 percent Massachusetts sales and use tax to certain types of computer system design and...more

10/3/2013 - Computer-System Design/Software Services Sales & Use Tax

Massachusetts "Tech Tax" Payment and Reporting Due Dates Deferred

In light of last week’s news that Massachusetts lawmakers intend to retroactively repeal the controversial “tech tax”, the Massachusetts Department of Revenue (“MDOR”) yesterday announced that it is deferring the September 20...more

9/18/2013 - Corporate Taxes Department of Revenue Repeal Reporting Requirements

Massachusetts Lawmakers Plan to Repeal the New “Tech Tax” on Computer System Design and Software Modification Services

On September 12, 2013, Massachusetts legislators announced their intention to repeal (with retroactive effect) the recent expansion of the 6.25 percent Massachusetts sales and use tax to certain types of previously untaxed...more

9/16/2013 - Business Taxes Corporate Taxes Repeal Software Developers Technology

Computer System Design and Software Modification Services Now Subject to the Massachusetts 6.25% Sales and Use Tax

Effective as of July 31, 2013, the Massachusetts 6.25% sales and use tax has been expanded to apply to certain types of computer system design and software modification services (“Computer/Software Services”)....more

8/2/2013 - Department of Revenue Sales & Use Tax Software

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