Tag Archives: s corp

Choosing the Right Transaction Structure for S Corporation Acquisitions

One unique aspect of acquisitions involving S Corporation targets is the availability of a Section 338(h)(10) election under the Internal Revenue Code. A 338(h)(10) election allows an acquirer of S Corporation shares to treat the transaction as the acquisition of assets, for federal income tax reporting purposes. This gives the acquirer a “step-up in basis” […]

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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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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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Mergers & Acquisitions: Who Gets the Employee Compensation Deduction?

What is more precious than the workforce that you have trained and nurtured over the years? Quite often, human capital-related tax issues stemming from ill-advised structuring and planning strategies create employee resentment.  This resentment can jeopardize employee goodwill and loyalty, affecting the overall long-term stability of your business model. As the saying goes, “you are […]

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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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