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Sales of Real Estate Involving Non-U.S. Sellers – FIRPTA Considerations for Both Parties

Transactions involving the disposition of a U.S. real property interest (“USRPI”) by a foreign person (i.e., a nonresident alien individual or foreign entity, the seller) are subject to the Foreign Investment in Real Property...more

M&A Tax Concepts: What is a “Gross-up Payment,” and Why Does It Matter?

Buying or selling a business is an exciting experience, and potentially lucrative opportunity for all parties. Most often, during the letter of intent / early negotiations phase, a “deal” is struck based primarily on economic...more

Qualified Small Business Stock – Overview and Useful Strategies

Founders, entrepreneurs, venture capitalists and other investors (all of which are collectively referred to herein as “investors”) should be familiar with Internal Revenue Code Section 1202, a valuable provision that...more

Preparing For 2025 Tax Filing Season

The end of 2024 is quickly approaching, and many are taking a moment (or two) to enjoy the Holiday Season. But as is always the case, after the New Year, taxpayers must turn their attention to tax filing season....more

Internal Revenue Service Warns of “Mills” Taking Advantage of Taxpayers With Offer in Compromise (“OIC”) Program

In a recent news release (available here), the Internal Revenue Service (“IRS”) warned taxpayers about promoters claiming their services are needed to resolve unpaid taxes owed to the IRS....more

Wealth Tax Fight Marches On

Proponents and opponents of proposed “wealth tax” legislation alike watched the Supreme Court carefully as it heard oral arguments for, and subsequently decided Moore v. United States on June 20, 2024. The crux of the Moores’...more

The Potential Impact of Expiring Tax Cuts and Jobs Act Provisions on Taxpayers

It’s hard to believe that the Tax Cuts and Jobs Act (“TCJA”) was enacted in late 2017 – almost seven (!) years ago. During that time, individuals and business owners may have become accustomed to the various changes brought...more

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