A common question we receive from founders is whether to organize their start-up business as a corporation or as an LLC. While there are many non-tax-related factors that need to be considered, this is often (at least in...more
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more
1/15/2018
/ Acquisitions ,
Alternative Minimum Tax ,
C-Corporation ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Net Operating Losses ,
New Legislation ,
Research and Development ,
Section 162(m) ,
Tax Cuts and Jobs Act ,
Tax Deductions
On July 13, 2017, the U.S. Tax Court issued its opinion in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner, in which the Tax Court held that a non-U.S. person who sells an interest in a partnership...more
8/21/2017
/ Capital Gains ,
Exemptions ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Selling a Business ,
Tax Court