Has the turmoil over the last year caused you to start thinking of selling your business? Or, perhaps, the pandemic has opened up opportunities to expand your business? One of the most compelling decisions you will need to consider in structuring a buy/sale agreement is whether to structure the deal
Generally, sellers of U.S. real estate are subject to U.S. taxation on capital gains arising from the sale of the real property. However, under the Foreign Investment in Real Property Tax Act (FIRPTA), the tax cost could be substantially higher. FIRPTA imposes a 10% withholding tax on the transfer (by
The Tax Cut and Jobs Act (TCJA) has brought significant changes to the U.S. taxation of foreign income. For decades, the income of certain foreign subsidiaries was only taxed in the U.S. upon repatriation of the income to the U.S. entity. The TCJA changed this deferral regime to a system
As you’re settling in for the holidays, and taking shelter from the winter weather with a warm fire and mug of cocoa, don’t forget to take one last look at your tax planning opportunities before the end of the year. The Tax Cuts and Jobs Act (TCJA) made major changes
Every five years, the Bureau of Economic Analysis (BEA), part of the US Department of Commerce, issues a mandatory survey that must be filed by US Persons engaged in certain foreign activity. The last survey was required five years ago, and it is due again in 2018. There is no
In a recent, well-reasoned case, the Sixth Circuit upheld a taxpayer’s use of an IC-DISC as a Roth IRA investment to accumulate earnings tax-free. The investment was established by the following steps: Roth IRA owns shares of Holding Company (Holdco); Holdco owns shares in IC-DISC, a tax-exempt entity for export