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Tax Planning › Internal Revenue Service › Controlling Stockholders

Buckingham, Doolittle & Burroughs, LLC

Gifts of Private Company Interests to Charity Prior to Sale

Buckingham, Doolittle & Burroughs, LLC on

A planning technique that is known to most tax professionals is for an owner of a private company to gift an interest therein to charity prior to a sale. This technique is only of interest to taxpayers who are charitably...more

Kramer Levin Naftalis & Frankel LLP

Debt-Equity Dashed Expectations: Treasury and the Service Retain Onerous Section 385 Regulations

Kramer Levin Naftalis & Frankel LLP on

On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more

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