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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce in the United States (Part 2)
Introduction Part 1 of this series discussed the proposals adopted by various countries to impose taxes on the digital economy, particularly by taxing various types of digital advertising and other digital services. These taxes allow countries to re...
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IRS Issues (and Seeks Comments on) Standards for Qualifying an LLC as a 501(c)(3) Entity
Nov 08, 2021
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Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992,—1994, and eBay—1995), and social media platforms in the 2000’...
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Today in Tax: Spin-offs, Tax Elections, and Subpart F
Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...
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The Magic of Provisional Process
Jun 07, 2010
In an economy in which the trial attorney's triumphs are often foiled by an insolvent judgment debtor, prior secured creditors, and bankruptcy, we should all keep in mind the advantages that may be offered to our clients by prejudgment relief in the...
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Heads I Win, Tails You Lose: Should Developers Dissolve Their LLCs After Completing a Project? (Part 2)
Jun 26, 2009
The question whether real estate developers should dissolve their limited liability companies ("LLCs") that they typically create for development projects has been a hot topic for the past several years in Washington. As we reported in the November 2...
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