Succession planning is a critical aspect of managing small, closely held businesses, as the unexpected departure of a key leader can significantly disrupt operations and challenge the business's legal...
Entering into a letter of intent for an office lease agreement? Consult our playbook for valuable key provisions, alternative language provisions, and guidance for both landlords and tenants. Download...
In the complex world of M&A transactions, transition services agreements (TSAs) serve as critical bridges between deal closing and operational independence thus creating stability during organizational...
This practice note covers key legal and regulatory issues to evaluate, questions to ask, and documents to review in medical device or diagnostic technology deals, including M&A, investments, financings...
Blocker corporations are a common part of private equity (PE) structures and may be an effective tax planning tool because they effectively “block” the flow-through of taxable income at the corporate level for federal, state, and local income tax purposes. They are employed most often when a PE fund invests in a U.S. based business that is taxed as a partnership for U.S. federal income tax purposes. There, taxable income passed through on a Schedule K-1 by a portfolio company generally falls into the category of income “effectively connected with a U.S. trade or business” for foreign investors and unrelated business taxable income (UBTI) for U.S. tax-exempt investors. Foreign investors and others want to avoid this scenario, which can lead to a U.S. income tax filing requirement and a possible U.S. federal income and withholding tax impact.
READ NOW »
Related Content
Practical Guidance Updates
Featuring the latest updates from your Practical Guidance account.
Experience results today with practical guidance, legal research, and data-driven insights—all in one place.Experience Lexis+
* The views expressed in externally authored materials linked or published on this site do not necessarily reflect the views of LexisNexis Legal & Professional.