Corporate Taxation

  • The Wayfair Decision and its Effect on Income Tax Nexus

    By:
    Brian Gordon, CPA
    |
    Jan 1, 2019
    Nexus is a connection to a state or taxing jurisdiction that is sufficient for a business to be subject to their tax laws. The U.S. Constitution does not define nexus, but gives guidance under two separate clauses. The Due Process clause states that more than a minimal connection is required. 
  • Practical Sales Tax Considerations for Vendors in the Wake of Wayfair (Part I)

    By:
    Mark S. Klein and Joseph N. Endres, JD
    |
    Jan 1, 2019
    By now we’re sure you have all heard about the U.S. Supreme Court case South Dakota v. Wayfair, Inc. This case reversed over 50 years of precedent and completely changed the way states can administer their sales tax laws with respect to out-of-state vendors. 
  • Opportunities and Pitfalls of Advanced Life Insurance Planning Techniques

    By:
    Matthew E. Rappaport, Esq., LLM and Edward W. Gordon
    |
    Dec 1, 2018

    Life insurance seems simple on the surface, but is probably the most complicated financial product available on the retail market. Since licensing standards are not rigorous and do not require prior education or apprenticeship, and since training typically covers only the introductory topics necessary to make a sale, most life insurance professionals do not know the intricate details of how life insurance products work.

  • New U.S. Tax Law and the IRC Section 962 Election

    By:
    Charles Ladas, CPA
    |
    Sep 1, 2018
    With the ratification of the Tax Cuts and Jobs Act (TCJA), many U.S. taxpayers are reconsidering their business structures. The reason for this is that the tax provisions of the TCJA contain greater benefits for domestic corporations than other business entities and individuals. 
  • U.S. Taxation of U.S. LLCs: Concerns About ‘Hybrid’ Tax Planning

    By:
    Michael Galligan
    |
    Aug 1, 2018
    An important concern in dealing with the tax treatment of U.S. LLCs in non-U.S. tax jurisdictions is the extent to which their treatment as “hybrid entities” will cause them to run afoul of a growing campaign against tax planning seeking to take advantage of the inconsistent treatment by different countries and jurisdictions of major types of income and tax offsets. 
  • U.S. Taxation of U.S. Limited Liability Companies

    By:
    Michael W. Galligan
    |
    Jun 1, 2018

    This is the first of a three-part series on an introduction to the cross-border tax treatment of U.S. limited liability companies. Please look for the next two parts in the July and August issues.

  • PFICs: Current State of Affairs

    By:
    Paul H. Dailey, CPA, MBA
    |
    Apr 1, 2018
    Passive Foreign Investment Companies (PFICs) are still alive and kicking! The new law made only one structural change to the PFIC regime: limiting the PFIC insurance exception. 
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