Bar Exam Toolbox Podcast Episode 269: Listen and Learn -- Creation of Partnerships
An Alternative to Consolidations: Key Considerations for Management Services Organizations
Succession Planning to Safeguard Your Law Firm’s Future: On Record PR
Physician Partnership Agreements: Setting Yourself Up for Success
The Current Landscape of Bank-Fintech Partnerships - The Consumer Finance Podcast
Strategic Restructuring for the Future, Putting a Plan Into Action: A Conversation With Gloria Brooks on Building End-of-Life Partnerships
Into the Future: Modern Partnerships in Health Care Construction Delivery
NGE On Demand: Profits Interests: Granting & Receiving with Patty Cain and Josh Klein
PODCAST: Williams Mullen's Trending Now: An IP Podcast - Cause Marketing: Do’s and Don'ts
Navigating the LLC Jungle - I Know a Lawyer Podcast
Sitting with the C-Suite: Managing the Merger and Looking Toward the Future
Sitting with the C-Suite: Finding the Right Fit
Sitting with the C-Suite: AI as the Future of eDiscovery
Sitting with the C-Suite: Reveal's Acquisition of NexLP – Making Bold Moves by Leading with AI
Episode 021: Member Liquidity, Default Rules, and the Corporate-ization of LLCs: A Conversation with Dean Donald J. Weidner
Assessing the PE Partner’s Experience, Financial Track Record, and Culture: Critical Consideration #5 - Thought Leaders in Health Law Video Series
Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
Roetzel HealthLaw HotSpot: Optimizing Your Practice for Sale
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
[WEBINAR] Laying the Foundation for Maximizing Benefits Around Emerging Technologies
In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more
In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more
Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more
The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 9, 2020 – November 13, 2020... November 9, 2020: The IRS released Notice 2020-75...more
U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more
The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more
The Situation: On June 14, 2019, the IRS and U.S. Treasury released more than 500 pages of proposed, temporary, and final regulations addressing the taxation of U.S.-controlled foreign corporations. The Development:...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
French investments in the U.S. vary largely in terms of scale and nature, but whatever it is a small French startup only creating an even smaller U.S. subsidiary or a large French corporation acquiring and restructuring an...more
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-16 (the Notice) providing additional guidance regarding the transition tax in section 965 of the Internal Revenue Code of...more
Chief Counsel Advice 201741018 (the CCA), which was released on October 13, 2017, considers the manner in which losses of a non-US partnership should be allocated among the partnership’s US and non-US investors in connection...more
The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more
Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more
On July 13, 2017, in Grecian Magnesite Mining, Industrial and Shipping Co. SA v. Commissioner (149 T.C. No. 3 (2017), the U.S. Tax Court concluded that gain recognized by a foreign corporation upon redemption of its interest...more
According to recent statistics, immigrants and their U.S.-born children now number approximately 84.3 million people, or 27% of the overall U.S. population. The countries from which the largest numbers of these individuals...more
Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
I. Overview - On August 6, 2015, the Internal Revenue Service (the “IRS”) and the Treasury Department announced their intention in Notice 2015-54 (the “Notice”) to issue regulations (the “Future Regulations”) under...more
On August 6, 2015, 18 years after U.S. Congress authorized regulations under Internal Revenue Code Section 721(c), the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released Notice 2015-54 announcing...more
On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"),[1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of 1986 (the "Code") to...more