News & Analysis as of

Limited Liability Company (LLC) Audits

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Greenberg Glusker LLP

Decoding Franchise Tax Board’s Hot Button Areas: Drops and Swaps and Post-Closing Refinancing

Greenberg Glusker LLP on

Those of us in California who give advice regarding the structuring of IRC Section 1031 like-kind tax-deferred exchanges of real property are well aware that the California Franchise Tax Board (FTB) has an active program of...more

International Lawyers Network

Establishing a Business Entity in Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing a Business Entity in Liechtenstein (Updated)

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

International Lawyers Network

Establishing a Business Entity in Hungary (Updated)

Since 1990, the Hungarian economy is based on the principles of market economy and considers the freedom of economic competition as a priority. On such basis, the regulation of business associations went through significant...more

International Lawyers Network

Establishing a Business Entity in Belgium

I. INTRODUCTION - (i) Our law firm - & DE BANDT is a law firm with a multidisciplinary approach and a focus on complex litigation. It addresses legal issues within the European economy that are driven by digital...more

International Lawyers Network

Establishing a Business Entity in Austria (Updated)

1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more

Rivkin Radler LLP

N.Y. Sales Tax – Responsible Person Liability

Rivkin Radler LLP on

NY Needs the Revenue- A couple of weeks ago, the Tax Foundation released its latest “State Business Tax Climate Index,” which assesses a state’s tax system and compares it to that of other states. New York seems to be a...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

Rivkin Radler LLP on

Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

DarrowEverett LLP

Proposed SEC Rules Aim at Putting Private Funds More in Public View

DarrowEverett LLP on

Whether everyday Americans saving for retirement, college tuition, or their forever homes know it or not, there’s a chance that their money is tied, directly or indirectly, to private funds. Moreover, those Americans probably...more

Rivkin Radler LLP

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

Rivkin Radler LLP on

Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing A Business Entity In Liechtenstein (Updated)

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

International Lawyers Network

Establishing a Business Entity in Hungary (Updated)

Since 1990, the Hungarian economy is based on the principles of market economy and considers the freedom of economic competition as a priority. On such basis, the regulation of business associations went through significant...more

International Lawyers Network

Establishing A Business Entity In Austria (Updated)

In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability companies and joint-stock...more

Foley & Lardner LLP

Positioning Your Company for Venture Capital Financing

Foley & Lardner LLP on

Market rumblings indicate the current economic landscape is creating challenges for start­ups looking to raise money. By some accounts, early-stage startups have not (yet) seen much of an impact of the tightening market,...more

Bradley Arant Boult Cummings LLP

With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

Rivkin Radler LLP on

State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

International Lawyers Network

Establishing A Business Entity In Liechtenstein (Updated)

The Principality of Liechtenstein lies at the centre of Europe, nestled between Switzerland and Austria, next to the river Rhine. The form of government is a constitutional monarchy established on democratic parliamentary...more

International Lawyers Network

Establishing a Business Entity in Hungary (Updated)

Since 1990, the Hungarian economy is based on the principles of market economy and considers the freedom of economic competition as a priority. On such basis, the regulation of business associations went through significant...more

Foley & Lardner LLP

Supplier Alert: Key Changes in Stellantis/FCA New Terms and Conditions

Foley & Lardner LLP on

FCA US LLC and Stellantis N.V. (“FCA”) issued new purchase order terms and conditions, including Global Terms and Conditions – Direct Materials (Common to all regions) and a North America Exhibit A to Global General Terms and...more

International Lawyers Network

Establishing A Business Entity In Austria (Updated)

1. Introduction - In principle any national citizen or foreign national is allowed to establish a business in Austria. A company is defined as a partnership of at least two persons (exceptions for limited liability...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Lessons from the Tax Court: Smaldino v. Commissioner

A recent Tax Court case, Smaldino v. Commissioner, T.C. Memo. 2021-127, provides important lessons on gifting. The Tax Court found that Louis Smaldino understated the size of his gift to a trust set up for his children...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

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