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
New partnership audit and collection regime rules will soon go into effect, defining who can elect out and enabling the Internal Revenue Service to assess taxes directly against the partnerships it audits.
Originally...more
Private equity and venture capital funds often invest in portfolio companies that are formed as partnerships or limited liability companies. But these investments create certain problems for foreign limited partners (LPs) in...more
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