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Protecting Net Operating Losses and Monitoring Stockholder Accumulation

It is not uncommon for a corporation to have net operating losses ("NOLs") that may be carried forward from year-to-year, and may be used to offset the corporation’s taxable income in future years. A corporation’s ability to...more

Taxation of Cryptocurrency and Similar Transactions

Whether you’re an investor expanding your portfolio to include digital assets such as cryptocurrencies and tokens, a business that uses cryptocurrencies to engage in everyday transactions, or a crypto “miner," you need to...more

IRS Releases Much-Awaited Guidance on PPP-Loan-Related Expenses, But More is Still Needed

On November 18, 2020, the Internal Revenue Service ("IRS") clarified its stance on the deductibility of expenses paid or incurred by businessowners who participated in the Paycheck Protection Program (“PPP”) by issuing...more

Bonus Depreciation Finally Available for Qualified Improvement Property Placed in Service After 2017

If you’re reading this Legal Alert, then you may be one of the many business owners, real estate professionals, restauranteurs, or retailers who were disappointed at how the tax law changes enacted in the Tax Cuts and Jobs...more

The CARES Act Includes Many Tax Incentives for Businesses - Expands Ability to Take Losses and Deductions

On March 27, 2020 the President signed into law a historic $2 trillion stimulus package known as the Coronavirus Aid, Relief, and Economic Security ("CARES") Act to provide economic stimulus for the devastation resulting from...more

Payment Deadline Extended

In response to the COVID-19 pandemic, IRS Notice 2020-17 (the “Notice”) postpones to July 15, 2020, the due date for making a Federal income tax payment otherwise due on April 15, 2020. This relief is available for...more

Look Before You Lend: A Practical Discussion of Tax Issues to Consider When Lending to an Emerging Business

Private credit appears to be the dominating trend throughout emerging business markets. Businesses seeking to raise capital are finding private investors who, unsurprisingly, are looking to maximize yield, while at the same...more

Canadians Who Invested in U.S. LLPs and LLLPs Need to Rethink Their Choice of Entity

Historically, Canadian investors in U.S. partnerships benefitted from an extremely efficient income tax structure – i.e., a single level of tax, credit against Canadian taxes for taxes paid in the U.S., and an ability to...more

Incorporating a Partnership to Take Advantage of the Qualified Small Business Stock Rules (Update)

This is an update to a 2013 Legal Alert by Bahar Schippel and Bill Kastin titled: Excluding 100% of Gain From the Sale of Qualified Small Business Stock Acquired in 2013. Among the tax breaks included under the...more

Identity Theft Protection Services – Federal Income Tax Treatment

I. Executive Summary - The Treasury Department and the IRS are sensitive to the data security problems facing organizations, their employees and their customers and, as a result, have provided some welcomed...more

Federal Agencies Issue Guidance to Business Owners: A Forecast of Enforcement Trends

Over the past few months both the IRS and the Department of Labor (DOL) have separately issued guidance emphasizing the importance of proper worker classification and some of the more common employment tax-related issues...more

Global Connection - June 2015

The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more

New Requirement to File BE-10: Benchmark Survey of U.S. Direct Investment Abroad

Any U.S. person with a foreign affiliate is required to file the 2014 Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad by June 30, 2015 or face civil penalties between $2,500 and $25,000. Further, a willful...more

For-Profit Hospitals and Management Companies May Enjoy New Tax Benefits

The IRS recently issued a private letter ruling which allowed a for-profit medical group (e.g., a hospital) to benefit from losses sustained by its wholly owned physician medical group – and allowed this to occur in a state...more

1/22/2015

IRS Announces Offshore Voluntary Disclosure Modifications and Revised Streamlined Procedures

On June 18, 2014, the IRS made significant changes to the procedures pursuant to which U.S. Persons can disclose any failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), and/or an international...more

6/25/2014  /  FBAR , IRS , OVDP , Standards & Procedures

The Portfolio Interest Exemption: A Pretty Good Thing

You know what’s better than earning portfolio interest? Nothing. OK, that may be an overstatement. But for non-U.S. lenders looking to earn a return on their U.S.-based investments, with respect to paying U.S. taxes, that’s...more

Excluding 100% of Gain From the Sale of Qualified Small Business Stock Acquired in 2013

If you own a small business, it may be easier to raise money in 2013. This is because, among the favorable tax breaks included under the American Taxpayer Relief Act (the “2012 Act”), there is a temporary extension of the...more

Doing Business In Arizona - A Legal Guide

Contents: Part I: A Brief Factual Look at Arizona: - Population and Job Growth - Personal Income - Exports - Leading Industries - Location - Business Costs - Labor Force - Education -...more

1/5/2013  /  Business Ownership
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