Michael Tuchman

Michael Tuchman

Levenfeld Pearlstein

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Latest Publications


The Other Kind Of Corporate Tax Inversion

Tax inversions have been much in the news lately. What is reported in the popular press is a trend to reincorporating a US company abroad for lower effective rates of tax on non-US source income. In the middle market, such...more

5/21/2014 - Choice of Entity Conversion Corporate Taxes Inversion Tax Rates

S Corporations - Time To Drop Them!

Most of us know that S corporations are reasonably tax efficient from an operating standpoint: leaving aside Illinois replacement tax, only one level of tax is paid on company earnings (at the shareholder level). We also know...more

5/15/2014 - Asset Freeze Asset Protection Choice of Entity Corporate Conversions Corporate Taxes Estate Planning S-Corporation Tax Planning

Frank Aragona Trust: A Taxpayer Win

In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more

5/7/2014 - Investment Management IRC IRS LLC Materiality Real Estate Investments Residual Interest Tax Court Tax Exemptions Trustees Trusts

Tax Tail Wags The Dog: Misunderstanding Imputed Interest

Tax professionals (accountants and lawyers) have an unfortunate tendency to transmute tax rules into general legal rules. Worse yet is the tendency of tax professionals to spread the gospel, as it were, and create legions of...more

4/23/2014 - Gift Tax Income Taxes

The Series LLC: 10 Reasons To Just Say No

Most practitioners have now heard of “series” limited liability companies. Series companies (and series partnerships) have been around for quite some time now in Delaware and are becoming more familiar as series organization...more

3/26/2014 - Choice of Entity LLC Series LLC

Illinois Use Tax: A New (And Aggressive) Focus On An Old Tax

As a result of Illinois’ budget woes, Illinois has taken a renewed and aggressive interest in collecting state Use Tax. ...more

3/1/2011 - Sales & Use Tax Tax Amnesty Voluntary Disclosure

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