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Tax
May 20, 2025

Close Encounters of the Business Kind: Mastering Succession and Tax Planning for the Small Business

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...

May 20, 2025

Close Encounters of the Business Kind: Mastering Succession and Tax Planning for the Small Business

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...

May 13, 2025

Crossing Borders, Cutting Taxes: U.S. Tax Treaties in Global Transactions

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...

May 06, 2025

Global Moves: Tax Planning for Permanent U.S. Expatriation

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...

April 29, 2025

Harvard's Tax-Exempt Tango: When Academia Meets the IRS Two-Step

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...

April 22, 2025

What’s Your Taxable Income—If You Don’t Mind My Asking? Computing Taxable Income for Partnerships

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'...

April 15, 2025

Tariffs Bring Move toward Regressive Taxation

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...

April 08, 2025

In the Name of Conservation, I Dub Thee Tax-deductible: Conservation Easements and their Rules

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...

April 01, 2025

Please Sir! I Want to Keep More of What I Have: Focus on Senior Citizen Taxation (State and Federal)

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...

March 25, 2025

Business Profits Taxations and the Importance of Tax Treaties

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...

March 18, 2025

When the Tax Collector Comes Knocking: IRS Tax Collection

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...

March 12, 2025

How Will the IRS Function after DOGE Dismissals?

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...

March 04, 2025

Watch Out! Common Pitfalls with LLCs Taxed as S Corporations

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...

February 25, 2025

Branch Profits Tax: Key Considerations for Multinational Corporations

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,"...

February 18, 2025

Franchise Taxes: A Tax for the Privilege of Existing within a State

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...

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