When tax-exempt or non-U.S. taxpayers invest in U.S. businesses, unwanted and unintended U.S. tax obligations can follow without careful planning. Blocker corporations have become a common strategy employed...
Obtaining a Phase I environmental site assessment (ESA) is essential to conducting environmental due diligence for commercial real estate transactions. The goal of a Phase I ESA is to evaluate readily...
Artificial intelligence (AI) tools and resources are inundating the news, social media, professional seminars, and inboxes. AI is part of every conversation across industries and professional services...
Do you need guidance in defending against claims brought under the recently overhauled California's Private Attorneys General Act (PAGA)? Read Private Attorneys General Act in California: Defending...
Confidently present your case in chief to the Trademark Trial and Appeal Board (TTAB) with this opening trial brief that an opposer/petitioner (plaintiff) may use in an opposition or cancellation proceeding...
Private equity investments are a particularly important subject to a tax attorney involved in entity formations, equity issuances, and M&A transactions. This practice note discusses U.S. federal income tax considerations that arise in a preferred equity investment in an operating company organized and operated in the United States. It focuses primarily on the tax considerations applicable to U.S. investors, but also discusses certain considerations applicable to non-U.S. investors, foreign sovereign governments, and tax-exempt entities. Specifically, this practice note addresses preferred stock in a corporation, preferred interests in an LLC or partnership, the conversion of preferred into common interests, deductions, and classification considerations.
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