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Corporate Taxation

  • U.S. Taxation of U.S. LLCs: Concerns About ‘Hybrid’ Tax Planning

    Michael Galligan
    Aug 1, 2018
    An important concern in dealing with the tax treatment of U.S. LLCs in non-U.S. tax jurisdictions is the extent to which their treatment as “hybrid entities” will cause them to run afoul of a growing campaign against tax planning seeking to take advantage of the inconsistent treatment by different countries and jurisdictions of major types of income and tax offsets. 
  • U.S. Taxation of U.S. Limited Liability Companies

    Michael W. Galligan
    Jun 1, 2018

    This is the first of a three-part series on an introduction to the cross-border tax treatment of U.S. limited liability companies. Please look for the next two parts in the July and August issues.

  • PFICs: Current State of Affairs

    Paul H. Dailey, CPA, MBA
    Apr 1, 2018
    Passive Foreign Investment Companies (PFICs) are still alive and kicking! The new law made only one structural change to the PFIC regime: limiting the PFIC insurance exception. 
  • Cybersecurity for Accountants

    Patrick Buono
    Mar 1, 2018
    According to Forbes magazine, the global cost of cybercrime will reach $2 trillion by 2019. Warren Buffett considers cyber attacks “a bigger threat to humanity than nuclear weapons,” and Ginni Rometty, IBM President & CEO, describes cybercrime as “the greatest threat to every profession, every industry, every company in the world.” 
  • Accounting Methods for Construction Contracts

    Joseph Molloy, CPA
    Jan 1, 2018
    New York City is in the middle of its biggest office construction building boom in three decades, and residential spending—which includes spending on new construction as well as alterations and renovations—is projected to reach $11.6 billion in 2018, according to a New York Building Congress analysis of multiple data sources.
  • The Current State of Leveraged Partnership Structures and Liability Allocations

    Jorge Otoya, CPA and Jim Dubeck
    Nov 1, 2017
    One of the many benefits of using partnerships to conduct business is that a partner can include its allocable share of partnership liabilities in the tax basis of its partnership interest (“outside basis”). 
  • Tools and Techniques to Shield and Defer Taxes On Unrealized Stock Gains

    Thomas Boczar, ESQ., LLM, CPWA, CFA, and Elizabeth Ostrander, CFA
    Oct 1, 2017
    What strategies might investors consider to strategically manage their single-stock risk over a longer-term period? Exchange funds, stock protection funds, and completeness portfolios are the primary tools investors can use to manage their stock concentration risk over a long-term period.

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