The complexities of redeeming a partner’s interest in a partnership with payments over multiple years are increased when the redeemed partner receives a promissory note.
Editor: Rochelle Hodes, J.D., LL.M. Employer-provided health coverage is one of the most widely relied-upon tax-favored benefits in the Internal Revenue ...
Collaboration agreements, especially in the life sciences, sometimes unexpectedly transcend state boundaries, with consequences for companies’ apportionment and sales factor revenue sourcing.
The rules for qualified small business stock become more complex when it is held through a pass-through entity or when the ...
Tax-exempt hospitals should reassess how they document, report, and defend their benefit to the community to support continued exemption under Sec. 501(c)(3).
State authorities are increasingly scrutinizing companies’ escheats information regarding sourcing, dormancy tracking, and owners.
Assumptions of receivables are usually straightforward, but debt transfers can in some instances be disallowed or even be considered abusive.
A recent IRS letter ruling and Tax Court case illustrate, respectively, successful and unsuccessful positions regarding foreign investments in the United States as effectively connected income.
Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
The Supreme Court held that in a tax sale of property to pay a property tax debt, the measurement of “just compensation” to be paid to the property owner for the property under the Fifth Amendment’s ...
The rules for qualified small business stock become more complex when it is held through a pass-through entity or when the corporation operates through one or more partnerships. This article discusses ...
A Type D tax-deferred spinoff or split-off followed by an S election may be available if the reorganization meets the requirements of Sec. 355 and Sec. 368(a)(1)(D), including a valid corporate ...
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