Tax Court Giveth and Congress Taketh Away: Taxation of Sale of U.S. Partnership Interests by Foreign Persons and Impact on M&A Transactions

  The Tax Cuts and Jobs Act (H.R. 1) (the “Act”), signed by President Trump on December 22, 2017, implemented the most comprehensive overhall of the Internal Revenue Code of 1986, as amended (the “Code”) in decades. In particular, the Act overturned a 2017 Tax Court case, Grecian Magnesite Mining, Indus. & Shipping Co. v. […]

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Highlights of H.R. 1 (The “Tax Bill”), Formerly Known as the “Tax Cuts and Jobs Act,” Passed by Congress and Signed by the President

      On December 22, 2017, the President signed into law the tax bill, an extremely broad and all-encompassing piece of tax reform legislation. the following is a brief synopsis in tabular format of select key provisions contained in the tax bill which generally go into effect on January 1, 2018:   Tax Reform […]

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To “C” or Not To “C”? A Triumph of S-Election Form Over Substance

  For shareholders of S corporations and their advisors, avoidance of the potentially catastrophic tax consequences resulting from a “blown” S election is always an issue of paramount importance. Due to superior asset protection, limited liability, tax savings and self-employment tax benefits, many Florida business owners have opted to operate their businesses utilizing an entity […]

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Make Sure to File Entity Classification Election if Non-Default Tax Status Desired

The “check-the-box” regulations promulgated years ago by the U.S. Treasury Department allow an eligible business entity such as a limited liability company (“LLC”) to elect its classification for Federal income tax purposes (“Entity Classification Election”). An LLC with a single owner may elect to be taxed either as a corporation or as a disregarded entity […]

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