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Andy Immerman

About 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.

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

July 24, 2017 By Edward Tanenbaum, Andy Immerman, Stefanie Kavanagh and Scott Harty

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

Filed Under: Federal Tax Advisory, International Tax Advisory Tagged With: aggregate, Department of Treasury, entity, foreign investor, Grecian Magnesite Mining, INdustrial & Shipping Co., IRS, Obama Administration, Rev. Rul 91-32, SA, Section 741, Treasury, Trump, v. Commissioner

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

March 24, 2015 By Andy Immerman

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

Filed Under: Federal Tax Tagged With: federal tax, Tax

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