Category Archives: Federal Tax Advisory

Tax Act: Vote and Value

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Our Federal Tax Group explains the nuances tax reform brings to the definition of a U.S. shareholder, including a surprise for controlled foreign corporations.

  • U.S. shareholders
  • The vote or value definition
  • Controlled foreign corporations

Click here to read the full advisory.

Tax Change Planning

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With tax cuts likely coming, it might make sense to consider establishing a C corporation for some new businesses. Our Federal Tax Group offers tax planners several different ways of thinking. Tax Reform Act of 1986 Payment of dividends and stock buybacks Less advantageous structures Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Dual-Class Stock Blessing for Spin

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A new Letter Ruling from the IRS brings concerns for corporations looking at a spinoff. Our Federal Tax Group breaks down the guidelines and what they mean.

  • Dual-class structure
  • Debt
  • Delayed transfers

Read the full advisory here.

Federal Tax ADVISORY: Partial Worthlessness

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Don’t overlook claiming a deduction for partial worthlessness. Our Federal Tax Group provides a refresher on this useful tool.

  • Cross-border or brother-sister debt
  • A hard pill to swallow
  • Ordinary loss

Read the full advisory here.

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

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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

Federal Tax ADVISORY: Taxpayer Wish List

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The Treasury is open for business to change tax rules to ease your compliance burdens. Our Federal Tax Group points out a few regulations that could use some updating. Reduce red tape Regulations can ease the burden What's on your list? Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Fourth Circuit Economic Substance Doctrine

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The Tax Court takes on the Fourth Circuit's version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward. The Tax Court said no The peculiar things about the opinion The takeaway Read the full advisory here. [...]Read more