If goodwill is personal to a shareholder of a C corporation (or an S corporation with built-in gain), in the context of a sale of the corporation’s assets to a buyer, the shareholder may be able to sell the goodwill...more
As we previously reported, following the tax reform package passed in December, private equity limited partner investors based outside the United States are now subject to tax on gains from the sale of partnership interests....more
4/27/2018
/ Capital Gains ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Withholding Tax
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
3/19/2018
/ Capital Gains ,
Foreign Investment ,
Income Taxes ,
IRS ,
Limited Partnerships ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Withholding Tax
The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies.
In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public.
Dividends generally are taxed at ordinary income...more
7/8/2015
/ Australian Stock Exchange ,
Capital Gains ,
Dividends ,
Initial Public Offering (IPO) ,
IRS ,
Jurisdiction ,
London Stock Exchange ,
Nasdaq ,
Publicly-Traded Companies ,
Qualified Foreign Corporation ,
Securities and Exchange Commission (SEC) ,
Stock Exchange ,
Stocks ,
Tax Rates ,
Tax Treaty ,
Toronto Stock Exchange
On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more