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 continuity. Unlike large, publicly traded companies, these...
The United States has tax treaties with nearly 70 countries to prevent double taxation and curb tax evasion. These treaties, based on Article II, Section 2 of the U.S. Constitution, are reciprocal and generally apply to both countries involved. For U.S. citizens...
With multiple European and South American countries promising an affordable retirement, Americans are increasingly renouncing U.S. citizenship and expatriating, some gaining citizenship, outside the United States. Relinquishing U.S. citizenship (or green card status...
Harvard University’s tax-exempt status has been questioned by the Trump Administration—with Harvard responding that there is no legal basis for a revocation. The Administration’s action impacting Harvard flows from its letter on policy changes...
The most prominent tax characteristic of a partnership or LLC is that these entities are flow-through entities for tax purposes. Consequently, the entities do not pay taxes themselves. Rather, they report to the IRS their income and the partners' or members'...
Tariffs are generally considered a regressive form of taxation—that is, a tax burden that falls more heavily on lower-income individuals than on higher-income individuals, relative to their incomes. When tariffs are applied, the cost of goods subject to the...
Real property transactions involving easements granted in the name of conservation can yield tax deduction benefits to the grantor. While the validity of charitable contributions in this area is subject to scrutiny and deduction claims are prone to challenge by...
As the population ages and more taxpayers live on fixed incomes, both federal and state governments face challenges in determining the appropriate level of taxation for retirees. For federal income tax purposes, retirement income is generally fully includable in...
Explore the taxation of business profits under U.S. international tax treaties, focusing on the critical role these treaties play in preventing double taxation and clarifying cross-border tax obligations. This practice note explores the concept of permanent establishment...
In 2025, navigating the IRS's tax collection process is more critical than ever, as changing tax laws and economic shifts demand vigilance from both individuals and businesses. The IRS, armed with a formidable team of Revenue and Appeals Officers, is tasked...
Executive Order 14210 issued by the Trump Administration calls for a "critical transformation of the Federal bureaucracy," which provides, among other things, submission of a plan by the Director of the Office of Management and Budget (OMB) to reduce...
A limited liability company (LLC) can be taxed as an S corporation, but an S corporation is not always a good choice. Learn the tax options available to LLCs and the advantages and disadvantages of electing to be taxed as an S corporation. When evaluating the procedures...
The U.S. branch profits tax (BPT) is a critical component of the federal tax system, ensuring foreign corporations with U.S. branches face a tax burden similar to U.S.-incorporated subsidiaries. Imposed at a 30% rate on the "dividend equivalent amount,"...
Virtually every state has some type of franchise tax or fee that is imposed on domestic and/or foreign corporations as part of the cost of doing business in the state. The measure of franchise taxes varies from state to state. While some franchise taxes are measured...