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 by private equity (PE) funds, particularly in buyout transactions...
Private equity transactions refer to investments (and the sale or disposition of those investments) made by pooled investment vehicles (a private equity fund, venture fund, or other group of institutional investors) in the non-publicly traded securities issued...
With more than $4 trillion of tax increases scheduled to take effect at the end of 2025, given the sunsetting provisions of the Tax Cuts and Jobs Act (TCJA), 2025 will be the most consequential year for tax legislation since the 2017 enactment of the TCJA. Whatever...
IRS issued a reminder that employers who offer educational assistance programs can also use them to help pay for their employees’ student loan obligations through Dec. 31, 2025. These programs rely on I.R.C. Section 127 which permits up to $5,250 of qualifying...
For U.S. tax purposes, a company must comply with certain tax and transfer pricing considerations when structuring intercompany debt transactions. Considerations include application of the arm's length standards of Treas. Reg. § 1.482-2(a) , documentation...
For U.S. tax purposes, digital assets are considered property, not currency. A digital asset is stored electronically and can be bought, sold, owned, transferred, or traded. The tax definition of a digital asset is any digital representation of value recorded on...
Generally, the way an annuity is treated depends on the type of annuity and its inherent features and benefits. This practice note addresses the specifics of the treatment for fixed, variable, immediate, deferred, and hybrid annuities. Review how income taxation...
Cyrus D. Mehta and Kaitlyn Box, Aug. 19, 2024 "Although most U.S. citizens and lawful permanent residents must pay U.S. taxes on their worldwide income, the foreign earned inclusion exclusion (“FEIE”) allows some U.S. citizens and residents to...
Flexible spending arrangements (aka flexible spending accounts or FSAs) operate under cafeteria plans that are established under IRC § 125 . A health FSA is the most popular FSA, allowing funds contributed by the employee and/or employer (often as flex credits...
A common way for states and localities to supply needed capital facilities, such as buildings, roads, and libraries, is to finance them. Instead of competing with nongovernmental borrowers, most choose to use a special governmental advantage, issuing bonds whose...
In Loper Bright and Relentless , the Supreme Court expressly overruled Chevron U.S.A. v. National Resources Defense Council, Inc. , which had required federal courts to defer to reasonable regulatory interpretations of ambiguous statutory provisions. Now, when...
The best way to learn about the tax considerations for buyers and sellers in M&A transactions is to study the different M&A deal types. This practice note focuses on the typical tax consequences of mergers and acquisitions, organized by deal type (asset...
Current distributions, also known as non-liquidating distributions, are critical to a partnership's or limited liability company’s (LLC) operations since pass-through entities use current distributions to distribute earnings and other property to the...
The IRS identifies charitable contributions of conservation easements as potentially abusive transactions. Often encouraged by promoters and armed with questionable appraisals, IRS asserts that contributions of conservation easements can result in inappropriately...
Getting answers from the IRS can involve the Private Letter Ruling (PLR) process of submitting a detailed request to the IRS. It must include a complete statement of all facts relating to the transaction, a statement of the business reasons for the transaction...