When we talk about a business compensating its service providers — which can include employees, attorneys, brokers and real estate developers, to name a few — it can mean more than just paying wages, bonuses or fees. Many providers want more than a check; they want to share in, and...
Read MoreIf you own property and a business, there’s an obvious temptation to lease that property to the business. But be careful — you risk triggering the self-rental rule and catching the eye of the IRS. One creative couple tried to get around this by using an S corporation to lease their...
Read MoreThe IRS has issued three sets of regulations — final, temporary and proposed — addressing disguised sales of property involving partnerships, the allocation of partnership liabilities and several other issues related to partnerships. The regulations are largely intended to eliminate...
Read MoreTargeted capital allocations are becoming standard in new LLC or partnership operating agreements. Historically, operating agreements typically provided for income/loss allocations to the partners based on the safe harbor provided under IRC Regulation 1.704-1(b)(2). This was more of a “cash...
Read MoreCan my private company benefit from a corporate tax inversion? I’ve been asked this question more frequently over the last few years as corporate tax inversions have gained momentum in the media and attention from politicians. The answer is, while you may be able to undergo a conversion, it...
Read MoreAmerica is the land of opportunity. However, opportunity can mean additional tax considerations, especially for foreign individuals setting up a business on U.S. soil. It is imperative to structure the business appropriately from the beginning so as not to trigger any unintended U.S. tax...
Read MoreIt is about this time every year when CPAs remind their clients that any foreign bank and financial accounts must be disclosed to the U.S. Department of Treasury by June 30th. My colleague Ray Polantz explains the foreign bank account reporting (FBAR) requirements in greater detail in his recent...
Read MoreWe certainly have seen an increase in oil and gas activity throughout Northeast Ohio over the past few years. One of the great aspects of oil and gas deals is the flexible structures they offer. Common conveyances include leases, subleases, sales, production payments, sharing arrangements and...
Read More(And why does it matter?
Read MoreOftenin the establishment of a new partnership, one partner (the contributing partner) contributes an asset such as land or a building and other partners contribute cash. This is especially common in the real estate industry and is a nontaxable transaction under Internal Revenue Code (IRC...
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