In one of my favorite legal movies, A Few Good Men, the lack of evidence on a particular point is brought up when Demi Moore’s character says to Tom Cruise’s character that he knows that something is true. Tom Cruise’s character then exclaims “it doesn’t matter what I believe, it only matters what I can
Disagreements happen. In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders. Or, there may be acrimony amongst the shareholders for other reasons, as can often happen with family-run businesses. Regardless of the reason, sometimes shareholders simply want out.
Fortunately, the corporate income tax laws
With the IRS ERC moratorium still in effect, employers are carefully considering their options including litigation. Recently, the IRS indicated it was prioritizing low-risk claims while flagging others as problematic. With no clear end in sight for the moratorium, some employers are now considering litigation to obtain their ERC refund.
Law360 covered the topic on
In the upcoming months, the U.S. Treasury and the IRS will be defending regulations aimed at curbing what they deem abusive tax practices, such as the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Concurrently, the U.S. Supreme Court will review a case involving a defunct transportation company
On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth tax. The ruling preserves the tax laws related to foreign corporations that were ushered
U.S. persons with interests in foreign trusts often have complicated international reporting obligations. Aside from an IRS Form 3520, these persons may have separate requirements to file IRS Form 3520-A. Worse yet, the penalties for failing to file a timely and proper IRS Form 3520-A can be severe. This article discusses five important things
Gray Reed Partners Austin Carlson and Cleve Clinton will be speaking at TXCPA Houston’s CPE by the Sea continuing education event on June 12, 2024, at the SouthShore Harbour Resort & Conference Center.
Austin’s session at 2pm will provide a top ten rundown of tips and traps related to 1031 exchanges. This will cover the
Gray Reed Partner Austin Carlson will be speaking on a panel webinar hosted by the Enterprise Europe Network, the world’s largest business service provider.
Scheduled for April 18, 2024, at 4 pm CST the FREE webinar will focus on the tax implications for European companies entering the US market and will provide insights into:
Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful lives lasting longer than the current tax year are capitalized. However, IP as an asset class has several statutory cost recovery possibilities (§§ 162, 167
A recent U.S. Tax Court decision provides clarity to what the Internal Revenue Service (“IRS”) considers a limited partner for purposes of the ‘limited partner exception’ to the Self-Employment Contributions Act (“SECA”) tax under Code Sections[1] 1402(a)(3) and 1402(a)(13) (the “Limited Partner Exception”). The Tax Court held in Soroban Capital Partners