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Learn MoreThe 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...
Read MoreTargeted 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...
Read MoreCan 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...
Read MoreAmerica 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...
Read MoreWhen most people think of the research and development (R&D) tax credit, they think of manufacturing. However, other industries can also benefit from this credit. In my August 5th post, we discussed the basics of the R&D credit and how it applies to manufacturers. Now let’s focus on how the credit...
Read MoreDid 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...
Read MoreThe research and development (R&D) tax credit offers benefits for a wide range of research activities in a host of industries. This credit is not just for “white coat” researchers in a back laboratory. In fact, entities from manufacturers to technology and other service providers can realize...
Read MoreOver 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...
Read MoreOver 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...
Read MoreIt 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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