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Shareholders Tax Returns

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

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Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Rivkin Radler LLP

New York Sales Tax: When a Responsible Person Acts Irresponsibly

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Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more

Farrell Fritz, P.C.

When Trying to Discover Tax Returns in Business Divorce Litigation, Bring Your A Game

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In many, perhaps most New York business divorce lawsuits, tax documents play a key role. Equity holder status is essential for standing to sue – including to dissolve, to sue derivatively on behalf of the entity, to sue...more

Hahn Loeser & Parks LLP

Staging Your Business for Sale: The Benefits of Having a “Paper Trail” in Place

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Selling a business often becomes a second full-time job. For first-time sellers, the process can be overwhelming. Often, sellers are perplexed by the volume of document requests and the endless follow up inquiries from...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

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Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

Rivkin Radler LLP

When A Shareholder Loses Control of Their S Corporation

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If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint...more

Ward and Smith, P.A.

Tax Treatment of the Sale of Social Club Assets Upon Liquidation

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Since 1916, Congress has exempted from income taxation clubs formed to facilitate social interaction between its members.  As a result, country clubs, hunting and fishing clubs, college sororities and fraternities, and...more

Holland & Hart LLP

New Final Tax Credit Transferability Regulations Issued; Changes Minimal

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On April 25, 2024, the IRS and US Treasury Department issued the final regulations under Section 6418 of the Code, the provision that allows sales of certain tax credits, including credits for renewable energy production and...more

International Lawyers Network

Establishing a Business Entity in Thailand (Updated)

Thailand has a civil or codified law system. The main legal codification governing commercial aspects in Thailand is prescribed under the Civil and Commercial Code (“CCC”) and other related Acts which are issued from time to...more

International Lawyers Network

Establishing a Business Entity in Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Blank Rome LLP

New York Appellate Court Rules in Favor of S Corporation Shareholder Entitlement to New York QEZE Tax Credits

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In a pair of decisions, a New York State appellate court has annulled decisions of the New York State Tax Appeals Tribunal that reduced certain tax credits available to the individual shareholders of their S corporation....more

International Lawyers Network

Establishing A Business Entity In Thailand (Updated)

Thailand has a civil or codified law system. The main legal codification governing commercial aspects in Thailand is prescribed under the Civil and Commercial Code (“CCC”) and other related Acts which are issued from time to...more

International Lawyers Network

Establishing A Business Entity In Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Dorsey & Whitney LLP

DSU Plans May Run Afoul of U.S. Deferral Election Timing Rules Resulting in Adverse U.S. Tax Treatment

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A Canadian company adopting a deferred share unit plan (DSU plan) for its directors must consider U.S. tax implications for U.S. taxpayers. It is important to remember that U.S. citizens and U.S. residents for tax purposes...more

International Lawyers Network

Establishing A Business Entity In Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - Limited companies: Corporation and Limited Liability Company - When...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

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Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

Butler Snow LLP

IRS Provides Much Needed Transition Relief for New Schedules K-2 and K-3

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February 18, 2022 On February 16, 2022, the IRS issued a news release along with a set of “Frequently Asked Questions” on new Schedules K-2 and K-3, which must be filed with IRS Forms 1065, 1120-S and 8865. This guidance was...more

International Lawyers Network

Establishing A Business Entity In Cyprus (Updated)

Cyprus is an EU member state and a common law jurisdiction with a legal system similar to that of the UK. It is located at the eastern end of Europe linking 3 continents, Europe, Africa and Asia and it has a long and strong...more

Farrell Fritz, P.C.

Justice Platkin’s Primer on Shareholders’ Inspection Rights

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The books and records proceeding often is the first time that a dispute between a minority shareholder and the majority enters the courtroom. Suspicious of misconduct or mismanagement, the minority shareholder demands to...more

Freeman Law

The Tax Court in Brief - June 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of June 14 – June 18, 2021 - Bell Capital Management, Inc....more

Rivkin Radler LLP

Tax Changes In The Offing? “Close Scrutiny” Of Business Owners’ Economic Benefits Remains A Constant

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I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more

Farrell Fritz, P.C.

How Dealings Between Related Parties Doomed A Captive Insurer

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Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

International Lawyers Network

Establishing A Business Entity In Cyprus (Updated)

1. INTRODUCTION - Having been a former British colony for several years of its history (from 1878 until its independence in 1960), the legal system of the Republic of Cyprus (hereinafter “Cyprus”) follows, to a great...more

Freeman Law

It’s Not Too Late!—Untimely S Elections

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In my practice, I have seen various issues related to a taxpayer’s S election. Corporations potentially jeopardize their S election by unknowingly creating a second class of stock through convertible debt. Corporations,...more

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