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Archive for the Corporate Tax Structure Category

Trump/GOP Leaders Unveil Tax Reform Framework

President Trump and Republican leaders in Congress unveiled a framework for tax reform on September 27. The nine-page framework broadly describes tax proposals ranging from lower rates for individuals and businesses to repeal of certain tax preferences, but it leaves actual legislative language to congressional taxwriting committees.…

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Bill is Introduced to Increase Foreign Investment in U.S. Real Estate

Two senior members of the House Ways and Means Committee on April 30, Kevin Brady, R-Tex., and Joe Crowley, D-N.Y., reintroduced legislation, the Real Estate Investment and Jobs Bill of 2015 (HR 2128), which would remove a 1980s era tax provision that discourages foreign investment in U.S.…

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Interest Paid by Foreign Disregarded Entity Was U.S. Source Income

The IRS Chief Counsel determined that interest paid by a foreign disregarded entity of a U.S. domestic corporation to a foreign corporation was U.S. source income under Code Sec. 861(a)(1) and, therefore, subject to withholding under Code Sec. 1442. The foreign corporation payee was a controlled foreign…

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found…

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IRS and Treasury Take Action Against Corporate Inversions

The Treasury and the IRS have announced that they will be taking targeted action against corporations employing a technique known as a tax inversion in order to avoid taxation, and have issued a fact sheet and a Notice in that respect. What happens with an inversion, is…

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Advantages & Disadvantages of Making an S Corp Election

Entrepreneurs often struggle with how to structure their business.  My clients often pose this question to me, as they should, while trying to make sense of the advantages and disadvantages of each corporate structure. Essentially, the most simplest structure is to be a Sole Proprietor.  But it is…

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