How Tax Works - Entity Selection
The Best of Founder Shares: Highlights Wisdom of Season's Guests
AGG Talks: Cross-Border Business - Economic Incentives for Foreign Companies Entering the U.S.
AGG Talks: Cross-Border Business - U.S. Tax Considerations for Scaling Across Borders
Nonprofit Quick Tip: State Filings in Alaska and Hawaii
Navigating Russia Sanctions
What Will the Corporate Transparency Act Mean for Your Business? [More with McGlinchey, Ep. 30]
Ledgers and Law: Start With an Ending in Mind When Building a New Business
Compliance Perspectives: Permissible Disclosures under HIPAA, Especially in the Time of COVID-19
Viewpoints: Portfolio Company Pension Liabilities
Asset Protection 101: Are You and Your Family Protected from Litigation, Creditors, and Divorce?
Episode 19: The LLC’s Two Worlds: A Conversation with Professor Peter Molk (Part One)
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Episode 1: Chris Mercer Interview on Marketability Discount: Part 1
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
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
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 13, 2021 – September 17, 2021... September 13, 2021: The IRS issued a news release...more
Due to COVID-19 closures at the Internal Revenue Service (IRS), EIN applications that are submitted by telephone, fax or mail currently are not being received or processed. Accordingly, non-U.S. applicants (who generally are...more
Opportunity Zones (or OZs) may be the most talked about provision of the Tax Cuts and Jobs Act of 2017. There are many twists and turns on the yellow brick road to completing an OZ project. This article sets forth the...more
Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more
The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more
In December, 2017 the Internal Revenue Service (IRS) released a revised Form SS-4, Application for Employer Identification Number and related instructions. An employer identification number (EIN) is a nine-digit number...more
On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more