Section 2115 is California's (in)famous pseudo-foreign corporation statute. In general, the statute subjects a corporation that is not incorporated in California to numerous provisions of the California General Corporation...more
On September 25, 2018, the IRS announced that it is undertaking a study regarding the application of the five-year active trade or business requirement of Section 355(b) (the “ATB Requirement”) to entrepreneurial ventures...more
On July 14, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 355 of the Internal Revenue Code that would establish new guidelines under the so-called "device" and "active business" tests....more