Corporate Taxation

  • 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. 
  • Cybersecurity for Accountants

    By:
    Patrick Buono
    |
    Mar 1, 2018
    According to Forbes magazine, the global cost of cybercrime will reach $2 trillion by 2019. Warren Buffett considers cyber attacks “a bigger threat to humanity than nuclear weapons,” and Ginni Rometty, IBM President & CEO, describes cybercrime as “the greatest threat to every profession, every industry, every company in the world.” 
  • Accounting Methods for Construction Contracts

    By:
    Joseph Molloy, CPA
    |
    Jan 1, 2018
    New York City is in the middle of its biggest office construction building boom in three decades, and residential spending—which includes spending on new construction as well as alterations and renovations—is projected to reach $11.6 billion in 2018, according to a New York Building Congress analysis of multiple data sources.
  • The Current State of Leveraged Partnership Structures and Liability Allocations

    By:
    Jorge Otoya, CPA and Jim Dubeck
    |
    Nov 1, 2017
    One of the many benefits of using partnerships to conduct business is that a partner can include its allocable share of partnership liabilities in the tax basis of its partnership interest (“outside basis”). 
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