Tax Business Organization

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Goodwill Owned by a Shareholder Can Provide Tax Planning Opportunities

A recent U.S. Tax Court case reminds us that the personal goodwill owned by the principal shareholder/employee can provide significant tax planning opportunities. Generally, the sale of assets by a "regular" corporation...more

Is Your Out-of-State LLC “Doing Business” in California?

Individuals and entities, including those from outside California, who invest in or do business through an out-of-state limited liability company (“LLC”) may be surprised to find out that they have filing obligations and tax...more

Plan Sponsor Should Avoid These Retirement Plan Provider “Con Games”

The George Clooney-Brad Pitt trilogy of heist films known as Ocean’s Eleven, Ocean’s Twelve, and Ocean’s Thirteen were remembered for their twist endings, stylish pacing, and lightheartedness. Since the Ocean gang were...more

IRS Introduces New Form 1023-EZ to Streamline Applications for 501(c)(3) Tax-Exempt Status

On July 1, 2014, the Internal Revenue Service (IRS) launched a new Form 1023-EZ, Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, that is intended to enable small...more

Plan Sponsors Should Avoid Using Their Payroll Provider as Their 401(k) TPA

I stick to what I know, so I venture very little outside the retirement plan space. I do that because I believe it is less likely to cause trouble. The two largest payroll providers don’t follow that philosophy -- they are...more

IRS Releases Streamlined Application for Tax-Exempt Status

The Internal Revenue Service (the “IRS”) has significantly streamlined the application process for small nonprofits seeking recognition as tax-exempt 501(c)(3) organizations through the release of a new application form on...more

Final Noncompensatory Partnership Options Regulations Could Affect the Tax Treatment of Penny Warrants and Other Arrangements

Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more

Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

Tax Law Blog: UPDATE: Form 1023 EZ Released for Small Nonprofits

It seems as soon as I blogged about the draft Form 1023-EZ, the IRS released the final form. So, this will serve as an update and follow-up to my June 30, 2014 post. on the Form 1023-EZ, the IRS has now released Form...more

A 401(k) Financial Advisor Shouldn’t Refer a TPA Just Because They’re Cheap

Animal Farm by George Orwell was a clever allegory of the Bolshevik Revolution and the Soviet Union where the oppressed animals overthrew Farmer Mr. Jones, only to start oppress- ing each other. A similar situation is when I...more

New York City Bar Association Report Offering New Proposed Guidance on the Treatment of a Partner as an Employee for Federal Tax...

This report, which was submitted on behalf of the New York City Bar Association by its Committee on Taxation of Business Entities, proposes new guidance, relating to the treatment of certain partners as employees for federal...more

Seed Capital Review: Fall 2013 Survey Of Angel Financings

Welcome to the first installment of Seed Capital review, written by members of the entrepreneurial Services Group at Gray plant mooty. this is our first periodic report analyzing seed capital being raised by companies in...more

Ocean Avenue LLC v. County of Los Angeles Affirmed; AB 2372 Passes Assembly

On June 3, 2014, in a published decision, the California Court of Appeal for the Second Appellate District affirmed the Superior Court ruling in Ocean Avenue LLC v. County of Los Angeles, holding that even though 100 percent...more

Legal Alert: MTC Speaks with Potential Transfer Pricing Vendors

On June 25, the Arm’s Length Adjustment Services Advisory Group (the Group) of the Multistate Tax Commission (MTC) met via teleconference to continue the process of developing a multistate arm’s length pricing adjustment...more

McKesson: Appellant’s Factum Filed

On January 10, 2014, McKesson Canada Corporation appealed the decision of the Tax Court of Canada in McKesson Canada Corporation v. The Queen (2013 TCC 404) (see Federal Court of Appeal File Nos. A-48-14 and A-49-14)....more

Bottom Line: This is what Retirement Plan Sponsors Need To Do

My great Uncle Jack Urbinder passed away a few weeks back at age 88. He was my Grand- mother’s only brother (out of 3) who survived the Holocaust. Much like my grandmother, Uncle Jack was genuine and he told it as he saw it....more

Congress Turns Tax World Upside Down with New Focus on Corporate Inversions

Interest in corporate inversions has revived on Capitol Hill. Recent publicity surrounding pending deals has triggered comments and legislative proposals from tax writers and other members and stirred up the debate about...more

ERISA Fiduciaries: Making Sense of All The Numbers

In the Golden Age of Boxing, there was one world champion. Whether it was Joe Louis or Rocky Marciano as the heavyweight kingpin or Sugar Ray Robinson as middleweight crown holder, you knew who was champion. There was one...more

Bank Regulators Require Changes To Tax Allocation Agreements

Acting in response to divergent results in recent court decisions, the Federal bank regulatory agencies have adopted an Addendum to their longstanding rules regarding income tax allocation agreements between insured...more

Retroactive Tax Planning

Converting Subpart F Income into Qualified Dividends - U.S. shareholders of foreign corporations are generally not subject to tax on the earnings of such corporations until the earnings are repatriated to the...more

New Simplified Conversion Process for Washington Corporations and Limited Liability Companies

Starting June 12, 2014, Washington law allows for the “conversion” of Washington corporations and limited liability entities into a variety of other business entities in Washington and other states through the simple adoption...more

French 3 Per Cent Tax on Distributions: French Subsidiaries of Foreign Companies Should Consider Claiming a Refund

Scope of The 3 Per Cent Tax - The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more

Plan Sponsors’ Misconceptions About Retirement Plan Fee Disclosure

To me, there is no greater television show than Seinfeld because it’s timeless and there is something about each episode that reminds you of normal day life. In the reverse chronology episode set in India called “The...more

Doing Business in Latin America and The Caribbean: Uruguay

With a geographical area of 176,215 square kilometers and a current population of 3.2 million inhabitants, Uruguay is one of the smallest countries in South America. Its current growth is 5% per annum. The Uruguayan...more

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