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Today in Tax: Three Things to Watch for in 2023
Jan 03, 2023
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Like clockwork, Americans greet each new year with soon-forgotten resolutions and unfounded predictions for the upcoming year. In keeping with that fine tradition,...
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A Non-U.S. Company’s Guide to Doing Business in the U.S.: A Playbook for Accessing the U.S. Market
For a printable PDF version of this article, please click here. For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies...
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Today in Tax: Digital Assets in Mergers & Acquisitions—Three Things Every Buyer Should Know
Cryptocurrencies, digital assets, and blockchain-based technologies seem to show up everywhere. As the market for these products matures, new markets are emerging. Competitors, new entrants, and investors are acquiring the technologies and platforms...
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Today in Tax: Tax Proposal Could Shake Up M&A For Corporations With Preferred Stock
Apr 19, 2022
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Brief commentary on the recent developments, cases, rulings, notices, and related federal tax guidance. Biden Administration Budget Proposal May Limit Tax-Free Reorganizations for Corporations with Preferred Stock Recent proposals may limit the abi...
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Today in Tax: Spin-off Structures in Mergers & Acquisitions
Nov 16, 2021
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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger Tax free spin-off transact...
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Goodwill Can Be Exchanged if Treated as Real Estate
Jan 06, 2012
When attempting to exchange a business, exchanging the goodwill component is often a dead end. Goodwill of two different businesses may never be of like kind. Treas Reg § 1.1031(a)-2(c)(2). Goodwill associated with real estate, however, can generally...
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