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Leto v. United States: How a Taxpayer’s Section 1202 Exclusion Could Have Been Saved

In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more

Limited Partners’ Tax Savings from Self-Employment Taxes are under Scrutiny

Hedge funds and private equity groups have long used the “limited partner exception” to minimize self-employment taxes, but on March 13, 2018, the IRS announced that it was going to increase its scrutiny on taxpayers...more

Business v. Nonbusiness Income: Categorizing Proceeds from the Sale of Equity Interests

Tax planning is often a vital consideration in an exit strategy for business owners. While most business advisors factor in federal income tax consequences when analyzing transaction structures, state income tax consequences...more

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