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...
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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...
S corporations allow small business owners to enjoy the limited liability and other advantages afforded by corporations while, at the same time, obtaining the flow-through benefits of partnerships or sole proprietorships. However, the tax treatment of S corporations is governed by subchapter S of the Internal Revenue Code (IRC) and has some significant differences from partnerships and limited liability companies. There are two primary limitations on the ability of S Corporation shareholders to deduct losses that pass through from the entity: (1) basis limitations, and (2) the at-risk amount limitations.
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