Investment Management Update – Exit Strategies
Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more
La Sección Cuarta del Consejo de Estado de Colombia, en sentencia del 3 de noviembre de 2022, expediente #23865, analizó los siguientes temas: 1) amortización del crédito mercantil en la compra de acciones; 2) la deducción...more
You have identified an Israeli target company to purchase. Now the question is – how to structure the acquisition? There are two traditional routes in Israeli private M&A transactions. The first is to purchase the shares of...more
Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more
Founder’s stock refers to the equity granted, typically in the form of common stock, to founders of a company for their preformation efforts in building the company. This common stock is sold to founders at a nominal value at...more
Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more