When tax-exempt or non-U.S. taxpayers invest in U.S. businesses, unwanted and unintended U.S. tax obligations can follow without careful planning. Blocker corporations have become a common strategy employed...
Obtaining a Phase I environmental site assessment (ESA) is essential to conducting environmental due diligence for commercial real estate transactions. The goal of a Phase I ESA is to evaluate readily...
Artificial intelligence (AI) tools and resources are inundating the news, social media, professional seminars, and inboxes. AI is part of every conversation across industries and professional services...
Do you need guidance in defending against claims brought under the recently overhauled California's Private Attorneys General Act (PAGA)? Read Private Attorneys General Act in California: Defending...
Confidently present your case in chief to the Trademark Trial and Appeal Board (TTAB) with this opening trial brief that an opposer/petitioner (plaintiff) may use in an opposition or cancellation proceeding...
In allowing a taxpayer to carryforward and carryback its net operating losses, the IRC recognizes the variability in corporate profits and the many reasons for this variability, especially for newly formed and restructured businesses. The IRC does not totally whipsaw taxpayers who have taxable years that produce losses that follow or precede profitable years. Instead, it allows taxpayers to offset their profits for tax purposes, at least to some extent, in one taxable year with the losses incurred in other taxable years.
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