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Results: 1-10 of 622

Does the U.S.- German double tax treaty also apply to a U.S. limited liability company?
  • Bryan Cave LLP
  • Germany, USA
  • April 29 2013

Whenever a U.S. Limited Liability Company ("US-LLC") is involved in cross-border shareholding structures concerning the United States


When and why to use the Section 83(b) election
  • Bryan Cave LLP
  • USA
  • August 26 2014

Start-up founders, executives and other employees should understand the role that Internal Revenue Code Section 83 plays in effective tax planning


Federal tax consequences of trust modificationreformation: score one for the taxpayer
  • Bryan Cave LLP
  • USA
  • June 13 2013

When is a modification or reformation of an irrevocable trust given effect for Federal tax purposes? In each of two recent private letter rulings


Disparate impact as applied to LIHTC programs
  • Bryan Cave LLP
  • USA
  • July 8 2015

The Supreme Court held in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. ("TDHCA Opinion") that a State's


IRS rules that conversion to unitrust in accordance with state law will not trigger loss of grandfathered protection
  • Bryan Cave LLP
  • USA
  • July 24 2013

A recent Private Letter Ruling (PLR 201320009) issued by the Internal Revenue Service (IRS) blessed a conversion of a grandfathered Trust to a


Supreme Court’s same-sex marriage ruling in Obergefell: effect on benefit plans
  • Bryan Cave LLP
  • USA
  • July 13 2015

Two years after recognizing same-sex marriages for purposes of federal law, the U.S. Supreme Court has gone a step further, requiring that all states


Comparison of exit transaction structure
  • Bryan Cave LLP
  • USA
  • November 19 2014

Because of taxes, the type of entity you have selected for your company may substantially impact the amount of money shareholders take home after


Five key considerations when drafting a release
  • Bryan Cave LLP
  • USA
  • July 3 2014

Separation agreements almost always contain release provisions whereby one or both parties agree to waive claims that they may have against the other


IRS rules on estate tax treatment of joint trust created in non-community property state
  • Bryan Cave LLP
  • USA
  • November 21 2014

Several non-community property states have recently enacted statutes authorizing the creation of a joint trust by spouses that would be treated as


Reporting target’s deductions in an acquisition
  • Bryan Cave LLP
  • USA
  • April 29 2013

Corporate clients often want a transaction to close at the beginning or end of the day. Generally, the reason for choosing the beginning or end of