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Seth Buchwald

About Seth Buchwald

Seth Buchwald is an associate in the Federal & International Tax Group. He uses his experience as a former certified public accountant (CPA) to understand and assist clients with their complex domestic and international tax planning and structuring issues.

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Get Out Your Crystal Ball: The Challenges of Tax Planning in the Current Age of Uncertainty

August 13, 2021 By Seth Buchwald and Brian Harvel

It is said the future is not yet written. But the Biden Administration has a draft ready for Congress. Our Federal Tax Group gazes into the Made in America tax plan to find the many questions that await within. The uncertainty of retroactive or prospective effective datesDeferring income recognition and accelerating deductions may not be the best planPrepare to reexamine traditional tax planning strategies Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: American Jobs Plan, Infrastructure

Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences

March 23, 2021 By Jasper L. (Jack) Cummings, Jr. and Seth Buchwald

Beware of being shortsighted. Last week, our Federal Tax Group takes the long view for borrowers and their creditors seeking to use short sales to extricate themselves from nonrecourse debt. What is a short sale?Is the short sale one integrated transaction or two separate ones?Two federal court cases tell the story Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: cancellation of indebtednes, CODI, covid-19, Fifth Circuit Court of Appeals, nonrecourse debt, Section 1001, Section 108, short sales, U.S. Tax Court

IRS Issues CARES Act Guidance Addressing Tax Issues Prevalent in M&A Transactions

December 4, 2020 By John Baron, Scott Harty, Daniel Reach and Seth Buchwald

The CARES Act’s Paycheck Protection Program (PPP) was a boon to many businesses, but some of its particularities have become a headache to acquiring taxpayers. Our Federal Tax Group untangles how PPP loans affect employee retention credits and deductions. New IRS guidance for both equity and asset acquisitionsA revenue ruling confirming that certain expenses cannot be deducted Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: CARES Act, employee retention credits, ERTCs, IRS, Paycheck Protection Program, PPP

From Obscurity to Spotlight: The Section 962 Election

February 18, 2020 By Scott Harty and Seth Buchwald

In case you missed it's release right before the President's Day holiday weekend, our International Tax Group addressed an election under Section 962 available to individual U.S. shareholders of certain foreign corporations to be taxed as a C corporation, which before tax reform was a rarely utilized and often forgotten tool that has recently been thrust into the spotlight due to its potential benefits.

The rise in popularity of the Section 962 election
Smith v. Commissioner, an unfavorable ruling for U.S. shareholders receiving distributions of foreign earnings subject to a Section 962 [...]Read more

Filed Under: International Tax Advisory Tagged With: 962, C Corp, CFC, GILTI, Subpart F, Tax Cuts and Jobs Act, tax reform, TCJA

Another Chapter in the Effectively Connected Income Saga—IRS Issues Proposed Regulations on Sales of Partnership Interests by Foreign Partners

January 16, 2019 By Edward Tanenbaum, Daniel Reach and Seth Buchwald

The IRS gets granular on new Section 864(c)(8), created by the Tax Cuts and Jobs Act. Our International Tax Group examines the implications of the newest proposed regulations brought on by tax reform.

How Section 864(c)(8) codifies longstanding IRS principles on effectively connected income
The proposed regulations’ complex formula for deemed partnership asset sales
Application to tiered partnerships and treaties

Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: ECI, IRS, recian Magnesite Mining v. Commissioner, Section 1446(f), section 864(c)(8), Section 897(g), Tax Court, Tax Cuts and Jobs Act, tax reform, TCJA

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