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Subsidiaries Pass-Through Entities

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

Venable LLP on

Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

Kramer Levin Naftalis & Frankel LLP

Flow-through Tax Status as a Property Right? The Case of Schroeder Brothers Farms

A recent case from the Western District of Wisconsin, In re Schroeder Brothers Farms of Camp Douglas LLP, may raise a new issue for the bankruptcy treatment of tax attributes in flow-through entities. The court in Schroeder...more

Holland & Knight LLP

Main Effects of U.S. Tax Reform on Foreign Taxpayers

Holland & Knight LLP on

President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more

Greenberg Glusker LLP

Escaping Taxes in Bankruptcy Through S Corporations

Greenberg Glusker LLP on

Shareholders of financially troubled S corporations may now be able to avoid the flow-through of taxes when the S corporation or its subsidiary files bankruptcy. ...more

McDermott Will & Emery

IRS Issues Another Significant Ruling on Spin-off of Real Estate

In certain recent transactions, a corporation distributes a subsidiary corporation holding the distributing corporation’s real estate assets to the distributing corporation’s shareholders in a tax-free “spin-off.” Not only...more

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