This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more
In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary. This year, in a multi-part article, I intend to take our blog...more
Most entrepreneurs creating high-growth startups in the US form their companies without giving much thought to maximizing their potential tax benefits at the time of sale. The conventional wisdom is to form a Delaware C...more
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
Our Federal Tax Group highlights a rule that exempts certain small business stock sales from taxes. What kinds of small companies are ideal candidates for qualified small business stock (QSBS) gain exclusions?...more
Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Model Rules for a Global Minimum Tax Companies should start preparing for the implementation of the OECD’s global minimum tax...more
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met,...more
On September 15, 2021, the House Ways and Means Committee approved its draft tax legislation that was released on September 13, 2021, as part of the “Build Back Better” budget reconciliation program. Included in the draft...more
Proposal’s Effect Would Limit Access to Capital for Small Businesses - An overlooked provision of the new, sweeping tax bill currently under consideration by Congress as part of President Joe Biden’s $3.5 trillion...more
With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more
If the Democrats Win- Science has not established – at least to my knowledge – any correlation between the pre-election year-end activities of individual business owners, on the one hand, and election outcomes, on the...more
In the excitement of starting a new business, and during the headaches associated with growing that business, many entrepreneurs overlook important details that can have huge impacts on their finances. One large blind spot...more
In Maryland, you can make a beneficiary designation on your real property. This type of transaction is called a Life Estate Deed. It can be a very useful tool to avoid probate while also preserving tax benefits. There are two...more
The IRS has released proposed regulations implementing the new centralized partnership audit rules. These regulations are virtually identical to the regulations that were released and then pulled in January of this year. ...more
The Protecting Americans from Tax Hikes Act, passed in December 2015, extended an often overlooked provision of the tax code with the potential to provide significant savings to small business owners and non-corporate...more
In the recently released Private Letter Ruling 201628002, the IRS determined that taxpayers were entitled to partial gain exclusion for the sale of their principal residence. Despite not using the property as their principal...more
Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more
The new regulations will have a direct impact on the formation of partnerships in the international context. For most of the past decade, contributions to partnerships (including LLCs taxed as partnerships) have been...more
In PLR 201609003, the IRS determined that a taxpayer was entitled to exclude gain attributable to the forced transfer of the taxpayer’s ownership of public use facilities, even though the taxpayer did not hold legal title to...more
Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more
What happened? On December 18, Congress passed and the President signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”), a measure that, among other things, retroactively renews, extends and...more
Tax law change is good news for non-corporate investors. On December 18, 2015, President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) into law. The PATH Act retroactively renews and...more
The Protecting Americans From Tax Hikes Act of 2015 (the "PATH Act"), expected to be soon passed by Congress and signed into law by President Obama, permanently extends the 100% exclusion for gain recognized on the sale of...more