California LLC Laws And IRS Identity Theft Reporting

The Biden Administration Corporate Tax Proposal

A discussion on the tax history of LLC entities in California as well as information on the IRS’s Fraud Reporting Division

Venture Capital: Investing In The European Marketplace

Venture Capital: Investing In The European Marketplace By Stephen McLaughlin As anyone who has ever tried it knows, As anyone who has ever tried it knows, venture capital investing is not a game for the weak of heart. While it is certainly true that some venture capitalists have accumulated massive investing is not a game…

THE LANGUAGE OF TRUSTS

The Language of Trusts

The Language of Trusts Many professions and disciplines have their own vocabulary. As an example, think about the terminology used in medicine and law. Often this vocabulary defines complex ideas, yet just as often “terms of art” can be defined with relative ease to a layperson. Such is the case with much of the language…

Tax Planning Considerations

Tax Planning Considerations First Year Tax Issues Upon Becoming a US Resident If a married taxpayer wishes to file a joint return, both spouses must be residents at the end of the year and elect to be treated as U.S. residents for the entire year. If the taxpayer is taxed as a U.S. resident for…

Approaches to Valuing Cost Sharing Buy-Ins

Approaches to Valuing Cost Sharing Buy-Ins Buy-Ins: Introduction Buy-in payments are often associated with a cost sharing arrangement (CSA) transaction. See § 1.482-7 for regulations regarding cost sharing arrangements between related parties. Participants should receive arm’s length compensation (a “buy-in”) for “pre-existing” intangibles that are contributed to a CSA. The buy-in should be treated as…