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New U.S. Tax Law and the IRC Section 962 Election
Corporate Taxation
With the ratification of the Tax Cuts and Jobs Act (TCJA), many U.S. taxpayers are reconsidering their business structures.…
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U.S. Taxation of U.S. LLCs: Concerns About ‘Hybrid’ Tax Planning
Corporate Taxation
This is the final part in a three-part series on an introduction to the cross-border tax treatment of U.S. limited liability…
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U.S. Taxation of U.S. Limited Liability Companies
Corporate Taxation
This is the first of a three-part series on an introduction to the cross-border tax treatment of U.S. limited liability…
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PFICs: Current State of Affairs
Corporate Taxation
Passive Foreign Investment Companies (PFICs) are still alive and kicking! The new law made only one structural change to the…
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Cybersecurity for Accountants
Corporate Taxation
According to Forbes magazine, the global cost of cybercrime will reach $2 trillion by 2019. Warren Buffett considers cyber…
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Accounting Methods for Construction Contracts
Corporate Taxation
New York City is in the middle of its biggest office construction building boom in three decades, and residential…
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The Current State of Leveraged Partnership Structures and Liability Allocations
Corporate Taxation
One of the many benefits of using partnerships to conduct business is that a partner can include its allocable share of…
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Tools and Techniques to Shield and Defer Taxes On Unrealized Stock Gains
Corporate Taxation
This article is the second in a two-part series about the tools and techniques to shield and defer taxes on unrealized…
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Tools and Techniques to Shield, Defer Taxes on Unrealized Stock Gains
Corporate Taxation
Investors with highly appreciated stock positions face a challenging environment. The stock market is at record heights,…
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