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Business Owner Exit Planning: LLC Operating Agreements
Sep 07, 2022
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Limited liability companies (LLC or LLCs) are an attractive choice of entity for many non-public companies. An LLC is the preferred choice of entity for many advisors, including me, unless the facts warrant something different. The preference toward...
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Today in Tax: Digital Assets in Mergers & Acquisitions—Three Things Every Seller Should Know
Acquisitions in industries related to cryptocurrency and blockchain technology exploded in 2021 in comparison with the preceding two years. Early data suggest that 2022 will be another record year for these acquisitions. This is not surprising as blo...
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Today in Tax: U.S. Tax Treaty Updates—Chile, Croatia, and Hungary
Aug 03, 2022
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Brief commentary on recent cases, rulings, notices, and related federal tax guidance. International tax policy has been in focus for the past several years. The Organization for Economic Cooperation Development (OECD) proposals for a more harmonized...
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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: Qualifying and Keeping a Religious Organization Tax-Exempt Requires a Bona-Fide Tax-Exempt Purpose
Churches and religious organizations can both qualify as tax-exempt organizations described in Code Section 501(c)(3). In the case of churches, qualification can be achieved more simply than for a non-church. The allure of tax-exempt status can tempt...
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Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates
May 24, 2022
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Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the enhanced transfer pricing pena...
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