Tag Archives: partnership

Cross-Border Tax Planning: Deferral vs. Check-the-Box

A U.S. company has several options when it comes to planning for cross-border activities in a foreign country.  One option is for the U.S. company to conduct its business activities in a foreign country through a foreign branch.  The branch structure allows the U.S. company to operate directly in the foreign country without forming a […]

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Tax Planning Strategies for Doing Business Abroad

These days, many emerging businesses find themselves doing business abroad. Technology has drastically changed the traditional business model, enabling even a small business to operate globally.  Many companies often ask whether they should operate through their existing U.S. business (i.e., operate as an incorporated “branch”) or operate through a separate organized foreign entity. Quite often, […]

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Basic Tax Tips for Negotiating a Sec 338(h)(10) Transaction

In an acquisition scenario where an S Corporation is the target, it is common for the S Corporation’s shareholders and the qualified acquiring entity (the purchaser must be a corporation and/or members collectively of an affiliated group of corporations acquiring 80% of the underlying stock ownership of the target measured in terms of voting shares […]

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U.S. Taxpayers and Foreign Tax Credits

The U.S. federal tax system provides for the direct foreign tax credit and the indirect foreign tax credit.  U.S. taxpayers may claim the direct foreign tax credit as a dollar-for-dollar offset against their U.S. federal income tax liability.  The credit is claimed for foreign taxes paid directly by the U.S. taxpayer on foreign source income […]

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Important Tax Considerations When Selling Your Business

Ready to negotiate the sale of your business?  First you should sit down with your tax advisor to gain a general understanding of the major tax considerations and constraints that should be evaluated. Partnerships, LLCs, C Corps, and S Corps all have various entity-specific tax consequences that should be evaluated before making any decisions. The […]

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