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New Seller Due Diligence Responsibilities After the Midco Cases?
Federal Taxation
In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated…
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Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations
Federal Taxation
The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a…
Read More
Foreign Trust Reporting: Substance Over Forms? I Think Not
Federal Taxation
In a world dominated by data, the IRS’s role in data collection continues to expand. No longer is the agency’s sole focus…
Read More
Coming to America – Love, Marriage and Immigration
Federal Taxation
In the 1988 hit comedy, Coming to America, Prince Akeem, heir to the throne of Zamunda, flees his home country to escape an…
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Tax Haven, USA
Tax Compass
International tax structuring and cross border planning has always been a complex and evolving process. The massive leak at…
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Mortgage Interest Tax Deduction
Tax Compass
During every election cycle, a set of tax proposals set forth by candidates become topics for debate. Whether or not each…
Read More
IRS Proposed Regulations Concerning Basis Consistency and Reporting for Property Acquired from a Decedent
Estate Taxation
On July 31, 2015, President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015…
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The Panama Papers: A Reminder to Taxpayers That It’s Not Too Late to Clean Up Unreported Offshore Assets
Corporate Taxation
Recent Developments Over the past few weeks, a giant trove of information regarding individuals holding assets through…
Read More
Cause Marketing: Plan Carefully to Avoid Legal and Tax Pitfalls
Estate Taxation
In recent years, cause marketing efforts have grown more popular with charities and their commercial marketing partners.…
Read More
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