Author Archives: Andy Immerman

Andy Immerman
Andy Immerman is a member of the Federal & International Income Tax Group. He focuses on federal income tax planning and transactional work for corporations, limited liability companies and partnerships.  Read More

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

Written by , , and
Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

The Cloudy Status of a “Profits Interest” Holder as an LLC Member

Written by
Cumulus Radio Corp. v. Olson, U.S. Dist. Ct., C.D. Ill., March 10, 2015 The existence of federal jurisdiction in this case turned on whether an individual who held an unvested profits interest in a limited liability company (“LLC”), and whom the LLC considered a partner for tax purposes, was a “member” of the LLC under Delaware law.  The case illustrates some of the confusion commonly surrounding the nature of LLCs, LLC membership, and “profits interests.” Defendant Alpha at first admitted being a Delaware “corporation,” which, if true, would have given the court diversity jurisdiction.  [...]Read more