Taxes
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…
Offshore Voluntary Disclosure Program Still Open for Quiet Disclosures and Formal Disclosures
In January 2012, the IRS extended the Offshore Voluntary Disclosure Program. The program allows U.S. taxpayers to pay penalties and…
Worker Classification: Voluntary Classification Settlement Program vs. Section 530 Relief
The world of worker classification is still fraught with great uncertainty. The distinguishing factors between an employee and an independent…
Maximizing Sec 382 Limitation Calculations for C Corps
If you are a C Corporation with substantial net operating losses (NOLs) carried forward subject to IRC Sec 382 limitation…
The “Back Door” Roth IRA Contribution
The Roth IRA presents a great opportunity to put money away for retirement and withdraw it all, free of tax….
You Can’t Just Move to Florida
Georgia Taxation of Stock Options and Deferred Income (Nonqualified Options) By Mitchell Kopelman, partner-in-charge of Tax, and Jess Johannesen, SALT…
Exceptional Investor Tax Benefits Available
By Mitchell Kopelman, partner, and Ori Epstein, partner Owners of qualified small business stock may be eligible for a 100…
“C” Corp Reasonable Compensation
A recent case (TC Memo 2013-10) upheld the taxpayer’s deduction of compensation to its officer as reasonable. The taxpayer (a…
Tax Tip: Home Office Deduction Safe Harbor
In a newly issued Revenue Procedure 2013-13, effective for tax years starting on or after 1/1/2013, the IRS has created…
The Importance of Sourcing Software License Royalty Income
If a US company pays a royalty to a foreign company for the use of a software license, there is…