Tax Business Organization

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Cross-Border Update on Investing and Doing Business in the United States

In this Issue: - Indian FDI into the United States - Indian Imports into the United States - Formation of US Subsidiaries - Ownership - Liability of Equity Holders - Management...more

New Guidance From IRS On At-Risk Rules For LLC Member Guarantees

The IRS recently released a chief counsel memorandum AM2014-003 on LLC Member Guarantees of LLC Debt and “Qualified Nonrecourse Financing.” These memorandums are very helpful because they provide the IRS’ interpretation of...more

Stay Ahead Of The Curve When Choosing Desired Tax Treatment

A foreigner starting business in the U.S. usually hires attorneys for visas, leases and licenses. The tax advisor comes later, when returns loom. This tendency is unfortunate because entering the U.S. starts the clock for...more

When It’s Time To Hire An ERISA Attorney

When I tell people that I’m an ERISA attorney, most people (including attorneys) don’t know what I do. While I’m not going to do a Rodney Dangerfield impersonation and claim I get no respect, the fact is that many plan...more

Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

IRS Hits the “Pause” Button on PTP Rulings

Recently it has become standard operating procedure for the Internal Revenue Service (“IRS”) to declare moratoriums on the issuance of private letter rulings (“PLR”) in certain areas. These temporary (or, in certain cases,...more

Why Tax-Exempt Organizations Should Plan for Joint Ventures

Non-profit organizations, which are exempt from federal income tax under Internal Revenue Code section 501(c)(3) (each a “Tax- Exempt Organization”), may find it necessary or beneficial for their operational goals to enter...more

The Waiting Game: What to Do (and Not Do) While an Exemption Application is Pending

So, you have thoughtfully and thoroughly prepared the Form 1023 Application for Recognition of Exemption Under Section 501(c)(3) (“Form 1023” or “application”) on behalf of a charity, and filed it with the IRS along with a...more

This is What a TPA Does and Why a Retirement Plan Sponsor Should Hire a Good One

One of my favorite movies of all time is The Deer Hunter. It’s a story about the Vietnam War and the post-traumatic stress disorder a group of friends from Western Pennsylvania who were drafted together and fought alongside...more

Perspectives - April, 2014

In This Issue: - Making Our Downtown Better Every Day - It's Good To "B" In Deleware - The Wonderful World of Limited Liability Companies - Ohio Bill to Allow Schools and Camps to Procure Epinephrine...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

‘S Wonderful, ‘S Marvelous, ‘S Unreasonable

One of the reasons to choose an S-Corp instead of an LLC is tax savings. An S-corp does not pay any taxes at the corporate level, but instead all income is passed through to the shareholders, who are responsible for a number...more

LLC Preferred Interest Qualifies For Marital Deduction

In a recent private letter ruling, the question was raised whether an LLC interest that received a preferred return with additional LLC cash flow going to other common interests could qualify for the marital deduction if...more

How a 401(k) Financial Advisor Can Limit Their Liability

There is the old saying that the cobbler’s children have no shoes. I know that firsthand when my mother threatened to call an electrician because my father the electrician didn’t have time to do some electrical work in our...more

Proposed Tax Code Overhaul Introduced with the Tax Reform Act of 2014

On February 26, 2014, House Ways and Means Committee Chairman Dave Camp released draft (the "Discussion Draft”) that would substantially reform the current U.S. Tax Code (the “Code”). The Discussion Draft contains numerous...more

IRS Announces "Pause" in Issuing New MLP Qualifying Income Rulings

The Internal Revenue Service (IRS) has temporarily stopped issuing new master limited partnership (MLP) qualifying income private letter rulings The IRS is re-assessing what types of qualifying income private letter...more

A SWISS PRINCIPAL MODEL CASE STUDY: RESTRUCTURING A MULTINATIONAL CORPORATION THROUGH TERRITORIAL OPTIMIZATION

The Swiss Principal model has become an effective means to optimize the structure of multinational companies on a regional basis, maximizing efficiencies by restructuring EMEA-area procurement, distribution and sales...more

Top 5 Nonprofit Legal Issues of the Past Year

The IRS scandal, diverting assets, ethics and more – the annual list of issues that affected associations and nonprofits in the past year. 1. Nonprofit corporation law changes New York and the District of...more

Finance Bill 2014 Published

The U.K. government has today published the final text of the 2014 Finance Bill. As discussed in our previous Alert, issued on March 19, the Finance Bill includes...more

Doing Business in Latin America and The Caribbean: The Bahamas

The Commonwealth of The Bahamas is an archipelago spanning 100,000 square miles extending southeast from Florida to northern Hispaniola. The Bahamas has an estimated land area of 5,382 square miles made up of 700 islands ...more

Rev. Proc. 2014-24 Provides Taxpayers Relief When Missing Form 1122 On Joining A Consolidated Group

On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more

Proposed Section 752 Regulations Would Prohibit Bottom Guarantees And Impose Net Worth Requirements In UPREIT Transactions

The IRS has recently proposed regulations under Section 752 of the Code which, if finalized in current form, would radically change the use of guarantees in partnership transactions. Under these regulations, bottom guarantees...more

Gore Decided: Unitary Nexus Rejected; Economic Substance Test Clarified

Today, the Maryland Court of Appeals issued its highly anticipated decision in Gore Enterprise Holdings, Inc. v. Comptroller of the Treasury; Future Value, Inc. v. Comptroller of the Treasury. The court held that under the...more

Why Employers Should Sponsor a Retirement Plan

Starting and running a business is one of the hardest things out there and I know from experience in starting my own law firm. You start a business to make a living and when the need arises and when you can afford it, you...more

Legal Alert: Maryland Court of Appeals: Out-of-State Delaware Holding Companies Licensing Patents to Parent Company Doing Business...

Today, the Maryland Court of Appeals held that Maryland may tax out-of-state Delaware holding companies that license patents to their parent company, which was doing business in Maryland. Gore Enterprise Holdings, Inc. v....more

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