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One Big Beautiful Bill Act (OBBBA) Resource Center

The One Big Beautiful Bill Act (OBBBA) will have widespread impact for almost every taxpayer. Visit our OBBBA Resource Center regularly for continuing updates and guidance on the tax impact of this legislation to you and your industry.

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February 20, 2017 Kim Palmer

3 Opportunities to Look for in Your Next Lease

It’s imperative that landlords and tenants know the tax ramifications — for better or worse — of the language that’s built into their lease and ancillary agreements. And it’s just as important to be aware of tax-impacting items not found in any written agreement. Specifically, there are three areas...

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February 09, 2017 Angel Rice

DOL Watching Health & Welfare Plan Filings: Do You Need to File?

The potential requirement to annually file Form 5500 is one that’s not always top of mind for many businesses. The form is required by the Department of Labor (DOL) and IRS and details financial conditions, investments and operations of benefit plans. If you have more than 100 employees who...

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February 06, 2017

Environmental Due Diligence Can Preempt Costly Liability

If you buy property with environmental issues, you may be liable — even if you weren’t responsible for the presence of contaminants. To best protect yourself, be sure to include environmental review as part of your due diligence. Why Conduct Environmental Due Diligence The most obvious reason...

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February 02, 2017 Marie Brilmyer

New Tax ID Phishing Scam Targets Corporations, Schools and Nonprofits

There is yet another dangerous phishing scheme circulating once again this tax season involving W-2s that targets corporations, schools and nonprofits. In a recent IRS communication, IRS Commissioner John Koskinen has said that this particularly dangerous scheme could “result in the large-scale...

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January 26, 2017 Kim Palmer

4 Ways Partnerships Can Offer Equity-based Compensation to Service Providers

When we talk about a business compensating its service providers — which can include employees, attorneys, brokers and real estate developers, to name a few — it can mean more than just paying wages, bonuses or fees. Many providers want more than a check; they want to share in, and have a hand in...

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January 03, 2017 Sean Kilcher

Not-for-Profit Revenue Recognition for Exchange Transactions to Change

Revenue recognition, arguably one of the most difficult areas in terms of interpreting not-for-profit accounting guidance, is about to get a major overhaul. However, much of the difficulty and judgment that currently exist aren’t going anywhere.   Revenue recognition is an area that often trips up...

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December 19, 2016

Passive Activity Self-Rental Rule Applies to S Corporations

If you own property and a business, there’s an obvious temptation to lease that property to the business. But be careful — you risk triggering the self-rental rule and catching the eye of the IRS. One creative couple tried to get around this by using an S corporation to lease their property to their...

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November 01, 2016

IRS Targets Partnership Transactions and Liabilities with New Regulations

The IRS has issued three sets of regulations — final, temporary and proposed — addressing disguised sales of property involving partnerships, the allocation of partnership liabilities and several other issues related to partnerships. The regulations are largely intended to eliminate what the IRS...

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July 13, 2016 Kim Palmer

Targeted Capital Accounts: The New Standard in Partnership Operating Agreements

Targeted capital allocations are becoming standard in new LLC or partnership operating agreements. Historically, operating agreements typically provided for income/loss allocations to the partners based on the safe harbor provided under IRC Regulation 1.704-1(b)(2). This was more of a “cash follows...

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August 20, 2015 Ray Polantz

Is a Corporate Tax Inversion An Option for Private Companies?

Can my private company benefit from a corporate tax inversion? I’ve been asked this question more frequently over the last few years as corporate tax inversions have gained momentum in the media and attention from politicians. The answer is, while you may be able to undergo a conversion, it actually...

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May 19, 2015 Ray Polantz

LLC vs. C Corp: Entity Structures for Foreign Owners Starting a U.S. Business

America is the land of opportunity. However, opportunity can mean additional tax considerations, especially for foreign individuals setting up a business on U.S. soil. It is imperative to structure the business appropriately from the beginning so as not to trigger any unintended U.S. tax...

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October 31, 2014 Laura White

Tax Identity Verification Letter Could Mean Fraud: A Checklist of What To Do

Did you receive a letter from the IRS (specifically LTR 5071C) or a letter from the Ohio Department of Taxation asking you to verify your identity or suggesting you may be a victim of identity theft? If so, you’re not alone. And, in one respect, this letter is a good thing. It means that the...

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July 22, 2014 Lisa Loychik

Right-of-Way Payments for Shale Land Leases

Over the last few years many landowners have begun receiving cash bonus payments for land leases related to the Marcellus and Utica Shale boom. In our work with clients in the Marcellus and Utica Shale regions, we have seen a recent uptick in landowners receiving offers to sign "pipeline...

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July 03, 2014 Robert Velotta

Key Tax Considerations to Launching and Operating a 1940 Act MLP Fund

Over the past several years, there has been a significant increase in the number of Master Limited Partnerships (MLPs), the market capitalization of MLPs, and the number and type of investment products being offered to allow investors exposure to MLP investments. The purpose of this article is to...

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June 16, 2014

Filing the FBAR May Not Be Enough for Foreign Trusts

It is about this time every year when CPAs remind their clients that any foreign bank and financial accounts must be disclosed to the U.S. Department of Treasury by June 30th. My colleague Ray Polantz explains the foreign bank account reporting (FBAR) requirements in greater detail in his recent...

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May 29, 2014

Structuring Oil & Gas Deals: You Have Options

We certainly have seen an increase in oil and gas activity throughout Northeast Ohio over the past few years. One of the great aspects of oil and gas deals is the flexible structures they offer. Common conveyances include leases, subleases, sales, production payments, sharing arrangements and...

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January 28, 2014 Kim Palmer

When is a Property Sale Really a Sale?

When is a sale a sale? When does a deal really close? Is it when title transfer occurs? It’s not always that simple unfortunately. Title transfer is only one of the factors when determining whether a transaction is closed and a sale has been made. There have been tax cases in which title had...

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September 11, 2013 Robert Velotta

Transfers to Investment Companies: Pitfalls of Secs. 351 And 721

In many instances, property can be contributed to an entity by its owners in exchange for ownership interests, without gain or loss being recognized on the contribution. For corporations, the general rule under Sec. 351(1) is that “no gain or loss shall be recognized if property is transferred to a...

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September 13, 2012 Kim Palmer

Partnerships: Be Wary of Disguised Sale Rules

Oftenin the establishment of a new partnership, one partner (the contributing partner) contributes an asset such as land or a building and other partners contribute cash. This is especially common in the real estate industry and is a nontaxable transaction under Internal Revenue Code (IRC) Section...

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January 01, 0001

Case Study: Acquisition Strategy

Key Challenges The company was relatively young, yet it had experienced robust growth across a number of different product lines. Despite its robust growth, there were few internal resources available to support the execution of an acquisition. The company’s ownership had potentially...

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