AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
Why Cannabis Related Businesses Must Consider Legal and Tax Issues
THE ACCIDENTAL ENTREPRENEUR
In the context of mergers and acquisitions, an acquisition target’s qualified retirement plans, health plans, executive compensation arrangements, and benefit programs (referred to collectively as “benefit programs”) can all...more
As more real estate funds look to reorganise UK assets into REIT holding structures, we share our experience on what makes a smooth transition. The UK real estate investment trust (REIT) is experiencing a revival. Recent...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
Monetizing a business concept presents numerous considerations for ambitious entrepreneurs, but with careful forethought, founders can spend more time growing their business and less time worrying whether they made an...more
Episode #22 The Accidental Entrepreneur - The Optimal Corporate Set Up discusses the virtues and financial powers of creating your own business as a vehicle for ensuring your current and future financial stability. Consider...more
In April 2016, I wrote Part One of this series. You can read this article on JD Supra. Part One focused on the hobby loss tax rules. Four years later I am writing part two. Did I forget that I had written part one? Perhaps!...more
Recently proposed IRS regulations reverse the reasoning of several past IRS private letter rulings regarding the application of the $1 million compensation cap of Section 162(m) to UPREIT structures in publicly traded REITs...more
• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more
On June 2, 2017, the Internal Revenue Service (IRS) held in a private letter ruling that proceeds used to a fund portion of the new stadium for the Los Angeles Rams franchise of the National Football League (NFL) and received...more
On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more