The One, Big, Beautiful Bill Act (H.R. 1), recently passed by the U.S. House, introduces major changes to the Global Intangible Low-Taxed Income (GILTI) regime that could impact multinational corporations...
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This practice note covers how to respond to a complete response letter issued by the FDA as part of the agency’s new drug application (NDA) or biologics license application (BLA) process. Read...
Want to know how to balance the benefits of artificial intelligence tools against associated risks to employee privacy? Read our practice note, Artificial Intelligence (AI) and Employee Privacy , by Damon...
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Sometimes things aren’t what they seem. Take disguised sales in partnerships and other flow-through entities. A disguised sale occurs when a partner supposedly contributes property with a built-in gain to a partnership and then immediately, or a short time thereafter, receives a related distribution. The outright sale of the property would normally result in the taxation of the built-in gain while the alleged contribution and distribution are presumably tax-free. The transaction could be recharacterized as taxable on audit to avoid the apparent abuse.
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