News & Analysis as of

Corporate Taxes Liquidation

Latham & Watkins LLP

Charging Ahead: Grappling With the Characterisation of Fixed and Floating Charges

Latham & Watkins LLP on

The characterisation of fixed and floating charges remains a complex area, not least with respect to new intangible asset types. The key distinction between a fixed and a floating charge is well established as a matter of...more

Proskauer - Tax Talks

Summary of the Biden Administration’s Fiscal Year 2025 Green Book Tax Proposals

Proskauer - Tax Talks on

On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on

Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

International Lawyers Network

Establishing A Business Entity In Israel (Updated)

While there are a few different forms of “corporate” entities in Israel, this guide will focus on companies and partnerships as these are the entities that the non-Israeli businessman is most likely to set up or invest in if...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Rivkin Radler LLP

An S Corporation’s Sale of Real Property Following the Death of Its Shareholder

Rivkin Radler LLP on

Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more

Rivkin Radler LLP

Maybe Tax the Rich, but Not The Conversion of S corps into Partnerships – What Gives?

Rivkin Radler LLP on

Tax the Rich? A few days ago, an opinion piece that appeared in the Wall Street Journal began as follows: “President Biden’s effort to pass the largest tax increase in U.S. history is based on the verifiably false...more

Rivkin Radler LLP

Disposing Of Assets Under The Ways and Means Committee’s Proposals

Rivkin Radler LLP on

First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more

Conyers

The Revenue Rule in the Cayman Islands and British Virgin Islands

Conyers on

It is well established, under common law principles applicable in the Cayman Islands and the British Virgin Islands that claims for payment of foreign tax liabilities, or claims for the enforcement of foreign judgments for...more

Kramer Levin Naftalis & Frankel LLP

Flow-through Tax Status as a Property Right? The Case of Schroeder Brothers Farms

A recent case from the Western District of Wisconsin, In re Schroeder Brothers Farms of Camp Douglas LLP, may raise a new issue for the bankruptcy treatment of tax attributes in flow-through entities. The court in Schroeder...more

Eversheds Sutherland (US) LLP

Getting Something for Nothing: IRS Withdraws Proposed “Net Value” Regulations

In June 2005, the Internal Revenue Service (IRS) issued a package of proposed regulations providing that certain corporate liquidations, formations and reorganizations would not qualify for nonrecognition treatment if the...more

Smith Anderson

Unpacking Your LLC: Tax Considerations in Limited Liability Company Liquidations

Smith Anderson on

Has your LLC lost its luster? Has it outlived its usefulness as an asset management, asset protection, or, dare we say it, wealth transfer vehicle? Are you tired of discussing the company’s operations with the other owners?...more

McDermott Will & Emery

State Revenue Departments Misapplying Federal Tax Law

McDermott Will & Emery on

State income tax laws generally build on federal tax law. The typical pattern is to begin the calculation of state taxable income with federal taxable income and then to modify it by adding or subtracting items where state...more

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