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DLA Piper | USA | 8 Apr 2019

Profits interest grants and the new three-year holding period

The 2017 Tax Cut and JOBS Act changed the federal income tax consequences of and compliance requirements for receiving, holding and disposing of…

Shearman & Sterling LLP | USA | 17 Dec 2018

Base Erosion and Anti-Abuse Tax (BEAT): Government Issues Proposed Regulations

On December 13, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations (the “Regulations”)…

Greenspoon Marder LLP | USA | 13 Nov 2018

Cannabis Tax Alert: 280E vs. 199A

Owners of cannabis businesses that operate in pass-through form - LLCs, partnerships, sole proprietorships and S Corporations - need to consider if…

Greenspoon Marder LLP | USA | 9 Nov 2018

Cannabis Tax Alert - Opportunity Zones

We would like to call your attention to an important new set of federal tax incentives that will make it significantly easier to raise capital for…

Michael Best & Friedrich LLP | USA | 8 Nov 2018

Treasury and IRS Release Qualified Opportunity Fund Guidance

The U.S. Department of Treasury (the Treasury) and the Internal Revenue Service (IRS) recently released proposed regulations along with related forms…

Troutman Pepper | USA | 8 Nov 2018

Personal Goodwill: Opportunities for Buyers and Sellers

If goodwill is personal to a shareholder of a C corporation (or an S corporation with built-in gain), in the context of a sale of the corporation’s…

Pierce Atwood LLP | USA | 6 Nov 2018

Opportunity Zones: An Update

The federal Opportunity Zone (OZ) program, created in December 2017, has been a major topic of discussion for investors, businesses, and project…

Taft Stettinius & Hollister LLP | USA | 6 Nov 2018

Opportunity Knocks: Planning Under the IRS Opportunity Zone Proposed Regulations

On Oct. 19, 2018, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations and other additional guidance regarding…

Nelson Mullins Riley & Scarborough LLP | USA | 5 Nov 2018

The Impact of the GILTI regime on corporate and non-corporate CFC shareholders

The varying impact of the changes put forth by P.L. 115-97 (the "Act" or the act formerly known as the Tax Cuts and Jobs Act), requires proactive…

Venable LLP | USA | 5 Nov 2018

IRS Issues Proposed Regulations Under Section 199A

Section 199A of the Internal Revenue Code of 1986, as amended (the "Code"), has become one of the most talked-about provisions of the Tax Cuts and…
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