Current distributions, also known as non-liquidating distributions, are critical to a partnership's or limited liability company’s (LLC) operations since pass-through entities use current distributions to distribute earnings and other property to the...
The IRS identifies charitable contributions of conservation easements as potentially abusive transactions. Often encouraged by promoters and armed with questionable appraisals, IRS asserts that contributions of conservation easements can result in inappropriately...
Getting answers from the IRS can involve the Private Letter Ruling (PLR) process of submitting a detailed request to the IRS. It must include a complete statement of all facts relating to the transaction, a statement of the business reasons for the transaction...
Before filing a consumer bankruptcy, individual debtors must determine their outstanding tax liabilities for purposes of completing a means test and properly filling out their schedules. Individuals must also provide copies of their tax returns to the U.S. Trustee...
When acquiring a C corporation, you’ll need to understand the advantages and disadvantages of an asset acquisition and its tax implications. The terms are of great importance as they appear in an asset purchase agreement, and you’ll need to review each...
Mergers and other corporate transactions create complexities in many ways, payroll included. Should FICA restart or is the new corporation a successor to the former entity? Two methods exist in an asset purchase transaction by which a predecessor (seller) and successor...
A Form 5500 annual report is required both under the Internal Revenue Code (IRC) and the Employee Retirement Income Security Act (ERISA). The form has a variety of purposes, the most important of which is to facilitate enforcement of the requirements of ERISA as...
The label "inbound" is given to corporate reorganizations where property or securities are moved from a foreign jurisdiction to a U.S. jurisdiction. The major focus of this practice note, adapted from a chapter in Rhoades & Langer’s U.S. International...
A split-up transaction is a type of spin-off transaction that occurs when shareholders of a business want to part ways. The split-up may occur because shareholders want to take the business in different directions or they just may no longer want to work together...
Under IRC § 103(b)(2) , interest which would otherwise be excluded from gross income under IRC § 103(a) is instead subject to federal income taxation if the obligation is classified as an arbitrage bond. Arbitrage bonds are one of several exceptions to...
It’s not unusual for large employers to own or lease private jets to transport their top executives to business locations. All business travel is a tax-deductible business expense (and generally the costs related to the jet), but what if there’s a personal...
Section 527 of the Internal Revenue Code provides a broad tax exemption for Political Action Committees (PACs) involved only in campaign activity. Section 527 applies only to "political organizations." For a PAC to qualify, it must be organized and operated...
A private letter ruling request is a request to the IRS by a taxpayer (an individual, business, or other entity) requesting the IRS to address, in writing, a specific tax situation that applies to the taxpayer, inquiring about its status for tax purposes or the...
Section 311, Title III, of the USA Patriot Act (the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001) amended the anti-money laundering provisions of the Bank Secrecy Act to promote the prevention...
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