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...
Tax avoidance is having a moment, and this practice note highlights methods developed by the private equity industry to structure around adverse tax consequences. There is no “one-size-fits-all” approach to fund formation—funds often are comprised of multiple entities that invest side by side in the same investment or are formed to hold entirely different types of investments. The goal in structuring an investment product is to achieve the most efficient and cost-effective framework, given the form of management, investor base, and portfolio content, while concurrently paying the minimum tax at all levels. The most tax-efficient structure can often be the most administratively burdensome choice, however, so a balance must be struck between ensuring maximum business and tax efficiencies. READ NOW »
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