Corporate Taxation

  • Tools and Techniques to Shield and Defer Taxes On Unrealized Stock Gains

    By:
    Thomas Boczar, ESQ., LLM, CPWA, CFA, and Elizabeth Ostrander, CFA
    |
    Oct 1, 2017
    What strategies might investors consider to strategically manage their single-stock risk over a longer-term period? Exchange funds, stock protection funds, and completeness portfolios are the primary tools investors can use to manage their stock concentration risk over a long-term period.
  • Tools and Techniques to Shield, Defer Taxes on Unrealized Stock Gains

    By:
    Thomas Boczar, ESQ., LLM., CPWA, CFA, and Elizabeth Ostrander, CFA
    |
    Sep 1, 2017

    Investors with highly appreciated stock positions face a challenging environment. The stock market is at record heights, interest rates are steadily increasing, and risks seem to be lurking everywhere around the globe. 

  • Asset Protection Planning: An Accountant’s Guide to Domestic and Foreign Asset Protection Trusts

    By:
    K. Eli Akhavan, Esq.
    |
    Jul 1, 2017
    Accountants should have more than a passing familiarity with asset protection. There are three reasons: first, an accountant occupies a unique position in an individual’s personal and business life—he or she has unfettered access to the data comprising a client’s financial existence and operations.
  • Investments by U.S. Investors in Non-U.S. Businesses – Tax Planning and Effective Structuring

    By:
    Gerard O’Beirne, CPA, and Harold Adrion, JD, LLM
    |
    Jun 1, 2017
    Planning and effective structuring for U.S. investors investing in non-U.S. businesses can only be accomplished with an understanding of the various rules that impact cross-border transactions. 
  • Partnership Examinations After the Bipartisan Budget Act of 2015

    By:
    Dean L. Surkin, JD, LLM
    |
    Mar 1, 2017

    The playing field for partnership examinations changes next year, along with how the IRS collects tax on adjustments to partnership income. The partnership—rather than the partners—will pay the tax in the first instance. 

  • Major New Reporting Requirements for Foreign-Owned Single-Member LLCs

    By:
    Lisa S. Goldman, CPA
    |
    Mar 1, 2017
    The Treasury Department has clamped down on a key reporting exemption that foreign-owned, single-member limited liability companies (LLCs) previously enjoyed, significantly impacting any foreign person or entity with holdings in U.S. single-member LLCs that are disregarded for federal income tax purposes. 
  • Taxpayer Advocate Service: A Resource for Tax Professionals

    By:
    Kim E. Randle, Acting Local Taxpayer Advocate (LTA)
    |
    Jan 1, 2017

    The IRS's Taxpayer Advocate Service (TAS) can help you help your clients. If your client is having a tax problem that you haven’t been able to resolve on your own, our advocates may be able to help. Your client may be eligible for our help if his or her IRS problem is causing financial difficulty, or if you believe an IRS procedure just isn't working as it should.

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