The Internal Revenue Code imposes a variety of limitations and obstacles to individual taxpayers’ ability to deduct certain types of losses. There are generally three different types of losses covered...
A mezzanine loan is a type of subordinate loan that is indirectly secured by real property. Unlike a mortgage loan, which is directly secured by real property, a mezzanine loan is secured by a pledge of...
Rely on this new visual checklist from Practical Guidance – Healthcare to determine whether a data breach constitutes a reportable breach of protected health information (PHI) under the Health Insurance...
Mergers and asset sales can be viable alternatives for companies in financial distress seeking to avoid bankruptcy. Financially distressed companies also present unique opportunities for investors and...
Check out checklists for necessary steps for cancelling trademark proceedings or issuing a notice of opposition at the Trademark Trial and Appeal Board (TTAB). The checklists include coverage of general...
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.
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