Management service organizations, common in the health care industry, can provide certain tax advantages.
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Topics
Tax Planning; Tax Minimization
The close of deferral: Planning for the QOZ end game
Many investors in qualified opportunity zones face a large upcoming tax hit when their QOZ deferral ends. They should consider harvesting stock market losses in advance of it.
Sec. 280G and the evolving executive compensation landscape
The affiliated-group rules and other complications can require care in determining application of this excise tax on compensation paid in connection with a change of corporate control.
Tax considerations for foreign investment in US private credit
Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.
Seller beware: Repossessions in real estate installment transactions
Sellers financing a sale of real property are subject to gain recognition under Sec. 1038 if they repossess the property upon the buyer’s default.
Sec. 163(j) planning considerations
Businesses can explore several options to mitigate the interest deduction limitation under the Tax Cuts and Jobs Act.
Avoiding passive loss limitations on rental real estate losses
Strategies for using the $25,000 offset for rental real estate losses can include keeping income within its phaseout range and contributing the loss activity to a closely held C corporation.
Revisiting FIRPTA and return-of-capital distributions
Although the Foreign Investment in Real Property Tax Act applies to foreign holders of U.S. real property interests, U.S. real property holding corporations also may find it advantageous to apply for a withholding certificate.
Apportioning tax benefits among members of a controlled group
A controlled group can choose how it apportions tax benefits and other items among its members, with rules for certain credits and for pension and profit-sharing plans.
Sec. 174(d) in M&As: Risks and opportunities
Taxpayers and advisers should focus on understanding the risks and maximizing the benefits of Sec. 174 when involved in M&A transactions.
Aggregation rules affecting foreign-owned companies
Multinational businesses should carefully consider whether the aggregation rules may trigger the application of unfavorable tax rules for their U.S. subsidiaries.
M&A transactions: The value of sell-side tax diligence
This item highlights how sell-side tax diligence can mitigate risks.
Inflation Reduction Act implications for Sec. 355 distributions
This item examines the implications for distributions described in Sec. 355(a) that follow from the introduction by the Inflation Reduction Act of the stock repurchase excise tax and the corporate alternative minimum tax.
‘Blocker’ corporations: Considerations for investment fund managers
This item outlines several issues for fund managers to consider as they analyze how to use blocker corporations in their fund structures.
Taxation of employees’ use of corporate apartments
The use of a corporate apartment as part of business travel generally could be excluded as a working condition fringe benefit, provided substantiation and other requirements are met.
What the Inflation Reduction and CHIPS acts could mean for US importers
This item discusses what the Inflation Reduction and CHIPS acts could mean for U.S. importers, beginning with the CHIPS Act.
Marrying ESG initiatives to business tax planning
Companies must focus on how ESG initiatives affect financial performance, market position, and ability to execute strategy, and a key component should be tax policy and planning.
The Inflation Reduction Act’s energy- and climate-related tax provisions
This article provides a high-level summary of the changes and discusses their implications for taxpayers.
Memo removes IRS procedural requirements for economic substance arguments
The IRS no longer requires examiners to follow a four-step process for determining whether a transaction complies with the economic substance doctrine before a penalty can be asserted under Secs. 6662(b)(6) and 6662(i).
Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
