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Gary Edelson

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Apr 20

Branch Transactions – New Aggregation Election

Do you have a business that has a branch in a foreign country?  If so, new regulations will dictate how you determine your taxable income. Many businesses have a branch in a foreign country.  This may include conducting business in the foreign country through an… Read More

Jan 10

Final Section 987 Regulations for “Qualified Business Units”

In December of 2016, the Treasury issued final and temporary functional currency regulations that apply to certain types of so-called “qualified business units”. A qualified business unit or “QBU” includes a corporation.  In addition, activities of a corporation or an individual qualify as a QBU… Read More

Nov 09

New Disguised Sale Rules

One way of cashing out business assets involves contributing the business assets to an entity classified for tax purposes as a partnership in exchange for a minority interest in the partnership, where the partnership would borrow money on a full recourse basis and distribute the… Read More

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Tax
Sep 12

Stay in LLC Structure and Go Public Using an UP-C Structure

In the “old days” if your business was in an LLC classified for tax purposes as a partnership and you thought you wanted to take your company public, you were told by the investment bankers to convert your LLC to a corporation. Many new businesses… Read More

May 26

Professional Corporation that does not elect subchapter S – be careful of using yearend bonuses to zero out taxable income

Some professional entities are C corporations.  The case of Brinks Gilson & Lione, a professional corporation v. Commissioner, TC Memo 2016-20, points out the danger in operating a professional entity as a C corporation.  In Brinks, the professional corporation had a substantial number of attorneys… Read More

Apr 05

It’s Tax Time – Wake Up and Think About Taxes!

Sometimes it is better tax wise to rehab space than build new. The Protecting Americans from Tax Hike Act of 2015 or “PATH Act” provided several gifts to the real estate industry that favors rehabbing older buildings.  The PATH Act retroactively restored and made permanent… Read More