AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
Why Cannabis Related Businesses Must Consider Legal and Tax Issues
THE ACCIDENTAL ENTREPRENEUR
The Czech government introduced a consolidated proposal to fight growing budget deficits, consisting of cutting subsidies and otherwise mostly increasing taxes as of 2024. This is a high-level review of those tax measures...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
Despite Senator Joe Manchin’s (D-West Virginia) recent announcement that he would not support a comprehensive version of Build Back Better, we expect Congress will advance some parts of the legislation early in 2022. The...more
Part II of this series introduced a new recommendation for business owners and investors regarding the ideal corporate setup for existing or new small business owners. Part II provided a broad overview of the benefits of the...more
Best way to structure your business to own multiple businesses in real estate and investment activities. Key benefits: Management and Control, Asset Protection, No FICA and Medicare Withholding and Ability to stagger a tax...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
We kicked off our seventh year writing the Manufacturing Law Blog with Megan’s predictions for EH&S. Matt will weigh in about labor and employment issues next week....more
Con le recenti risposte alle istanze di Interpello n. 276 e n. 277, l’Agenzia delle Entrate (“Agenzia”) ha commentato la disciplina dell’articolo 14 del d.lgs. 472/1997 in materia di responsabilità solidale del cessionario (o...more
A partnership (or LLC) can go public in a highly tax-efficient manner by using an “Up-C” structure. An Up-C structure is composed of two entities: (1) a parent company, a C corporation (“PubCo”) which will be organized as a...more
The Tax Cuts and Jobs Act has been called a lot of things by a lot of different people. Certain provisions of the Act, however,coupled with recently proposed regulations thereunder, may result in its being known as the...more
The UK tax authority (HMRC) has announced a new Profits Diversion Compliance Facility (PDCF), as part of its efforts to ensure that multinationals do not use artificial arrangements to divert profit to lower tax...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
Establishing a business in the U.S. by a foreign corporation can be a fairly smooth operation with the right guidance and support. There are steps to take in forming, operating and growing a business in the U.S. in addition...more
Tuesday night the Senate passed the Tax Cuts and Jobs Act (the “Tax Reform Act of 2017”). The House was expected to re-vote on it yesterday. Kevin Brady, Chairman of the House Ways and Means Committee, and Paul Ryan, Speaker...more
When opening a new business, electing a business structure is an important decision. The business structure elected can affect how much will be paid in entity income taxes, record-keeping requirements, how much personal ...more