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Private Equity › C-Corporation

Hinckley Allen

Qualified Small Business Stock: Pre-Acquisition Planning for Tax Savings Upon Exit

Hinckley Allen on

Issuing qualified small business stock (“QSBS”) is a valuable tool that can provide significant tax savings to searchers and independent sponsors alike upon the eventual sale of one or more of their portfolio companies....more

Hanson Bridgett

United States Tax Planning for Foreign Founders Moving to the US: Planning for Qualified Small Business Stock Benefits

Hanson Bridgett on

Many non-US startup founders initially incorporate in their home country and then decide to reincorporate or create a subsidiary in the US. There are many advantages for foreign founders to move operations to the US,...more

Mintz - Tax Viewpoints

F-Reorgs: How Buyers’ and Sellers’ Favorite ‘F Word’ Optimizes M&A and Private Equity Transactions Involving S Corporations

Mintz - Tax Viewpoints on

In M&A and private equity transactions, buyers and sellers are consistently looking for ways to maximize value, which requires a critical focus on structuring the transaction in a tax-efficient manner. This pursuit of tax...more

Foley & Lardner LLP

The Tax Man Cometh: Tax Perils in Physician Recapitalization Transactions

Foley & Lardner LLP on

Physician recapitalization transactions are complex by nature and often present myriad issues. At Foley, in our representation of both investors in, and sellers of, physician practices, we note how often tax issues become...more

Ward and Smith, P.A.

So You've Been Watching (and Cringing at) HBO's "Succession"?

Ward and Smith, P.A. on

Let's discuss some less-dramatic exit options for business owners (when they want to step away). You may not run a global media conglomerate, but even closely held business owners (and perhaps especially closely held...more

Opportune LLP

How Section 83(i) in the Tax Cuts & Jobs Act of 2017 Benefits Workers

Opportune LLP on

The Tax Cuts and Jobs Act of 2017 (“The Act”) is just over a year old and tax practitioners, taxpayers and commentators are still working to digest the actual effect of many of its sweeping changes. While one of the central...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

McDermott Will & Emery

GILTI Rules Particularly Onerous for Non-C Corporation CFC Shareholders

McDermott Will & Emery on

The recently enacted tax reform legislation significantly expanded the application of Subpart F, including by adding a new inclusion rule for non-routine CFC income, termed “global intangible low-taxed income” (GILTI). The...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

Vedder Price on

On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

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