The Committee on Foreign Investment in the US (CFIUS) is an interagency organization that identifies commercial transactions that raise US national security considerations when there is significant foreign ownership of US...more
Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more
Those of you who followed the drama around the oddly-named Inflation Reduction Act of 2022 will have seen the rise and fall of efforts to change tax laws regarding “carried interests.”...more
In the government’s continuing effort to combat money-laundering, Congress recently passed the Corporate Transparency Act (CTA) to require private companies to disclose their “beneficial owners” to the U.S. Department of the...more
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
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
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
/ Internal Revenue Code (IRC) ,
Investment Management ,
IRS ,
Limited Liability Company (LLC) ,
Materiality ,
Real Estate Investments ,
Residual Interest ,
Tax Court ,
Tax Exemptions ,
Trustees ,
Trusts
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
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
As a result of Illinois’ budget woes, Illinois has taken a renewed and aggressive interest in collecting state Use Tax. ...more