Posted tagged ‘tax’

Houston – 36th Annual Tax and Business Planning Seminar

October 30, 2013

This must-attend seminar will help ensure that you are as ready as the IRS for 2014. Hosted by Best Lawyers-ranked Tier One taxation law firm Chamberlain, Hrdlicka, White, Williams & Aughtry, the event will feature presentations by Patrick Jankowski, CCR, Vice President, Research, Greater Houston Partnership, and more than 14 experts from Chamberlain Hrdlicka’s labor, transactional, planning, and tax controversy practices. Attendees can earn CLE/CPE/CFP credit.

December 5, 2013
Houston Marriott Westchase
Houston, Texas

Click here to register online

Click here for more information

Atlanta – 28th Annual Tax and Business Planning Seminar

October 28, 2013

This must-attend seminar will help ensure that you are as ready as the IRS for 2014. Hosted by Best Lawyers-ranked Tier One taxation law firm Chamberlain, Hrdlicka, White, Williams & Aughtry, the event will feature presentations by named shareholder David Aughtry, a former IRS trial attorney and the firm’s leading tax litigator for nearly 30 years, and 15 other experts from Chamberlain Hrdlicka’s labor, transactional, planning and tax controversy practices. Attendees can earn CLE/CPE/CFP credit.

Wednesday, November 13, 2013
Cobb Galleria Centre
Atlanta, Georgia

Click here to register online.

Click here for more information.

To Minimize Taxes For Years To Come, Consider Incorporating Your Business In 2013

April 22, 2013

By Dustin Covello

Choice of entity is one of the first and most important tax-planning decisions that any entrepreneur must make. Conventional wisdom holds that most entrepreneurs should organize their businesses as “pass-through” entities – primarily limited liability companies, partnerships, subchapter S corporations, or sole proprietorships. Pass-through entities are not themselves taxable. Rather, all of their income is “passed through” and taxable to their owners. By contrast, operating a business in the other main form – a corporation – subjects the business’s income to the dreaded “double tax” because the corporation itself is subject to tax, and then the shareholder is subject to tax when he receives dividends from the corporation or sells its stock at a gain.

Historically, the expense associated with the double tax has varied, depending on the prevailing tax rates, but it almost always exceeded the tax expense on pass-through income. At this unique time, however, entrepreneurs following the conventional wisdom may be missing a valuable tax-planning opportunity:  two features of the American Taxpayer Relief Act of 2012 make corporations much more attractive compared to pass-through entities. (more…)

By Appeasing the United Kingdom, Starbucks May Have Relocated Its Tax Problems Into The United States

December 12, 2012

By:  Dustin Covello

As one of many U.S. multinationals that reportedly implemented the Double Irish international tax structure, Starbucks has reportedly paid a U.K. tax rate of 2.8 percent over the last decade.  Not satisfied with this levy, last month the British Parliament called Starbucks and other U.S. multinationals before the body to discuss the structure.  Last week, in response to Parliament’s pressure, Starbucks announced that it would voluntarily forgo U.K. deductions to ensure it pays £10 million ($16 million) in tax during 2013 and 2014.  It remains to be seen whether Starbucks’ announcement will placate Parliament.  By making this gesture, however, has Starbucks caused a U.S. tax problem?  (more…)

Southgate Master Fund: The Sham Partnership Doctrine Gets Messy… Or Does It?

December 13, 2011

By Jonathan Prokup

Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States.  The appellate court had previously concluded that the taxpayer was not entitled to a claimed capital loss from a transaction involving the acquisition of distressed debt via a partnership because the partnership was a “sham” that should be disregarded for federal tax purposes.  The taxpayer’s petition for rehearing, along with two amicus briefs, raised the specter that the Fifth Circuit’s opinion would require taxpayers to have a non-tax business purpose for choosing to conduct business activities in a partnership rather than a corporation. (more…)

Businesses Prepare For The End Of The Euro; Will Treasury Do The Same?

November 29, 2011

By Jonathan Prokup

According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro.  Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., asset prices) and income statements (e.g., import costs).   (For additional FT coverage of the issue, see here.)

As we noted in the TaxBlawg a while back when the euro crisis was still focused primarily on Greece, a partial or complete breakup of the eurozone would give rise to a host of tax issues for U.S.-based multinationals.  Would a conversion from the euro to the drachma or the lira or another currency, as the case may be, create a realization event under Code section 1001?  Would the exchange give rise to currency exchange gain or loss under Code section 988?  Finally, if a taxpayer’s qualified business unit (“QBU”) were forced to switch its functional currency from the euro to a legacy currency, should that switch be considered a change in the taxpayer’s method of accounting for purposes of Code section 481?

The Treasury Department tackled these questions when the euro was first introduced.  It seems reasonable to think that they would follow a similar pattern but in reverse, essentially treating the conversion as a non-taxable event, while deferring any currency gain or loss until a subsequent disposition of the legacy currency.  Nevertheless, until taxpayers receive guidance from Treasury, the potential tax consequences of a eurozone breakup will remain one more area of uncertainty.

The Extenders Bill Is Dead. Long Live The Extenders?

June 29, 2010

By Jonathan Prokup

Now that the tax extenders legislation has died, what’s next?  At least some of the provisions (e.g., the new tax regime for “carried interests”) are likely to find their way into future legislation.  But what about the tax extenders themselves, such as the look-through rule of section 954(c)(6) and the section 41 research credit?  Although many of the extensions involve tax expenditures (i.e., provisions that cost the Treasury money), they would almost certainly be offset by the bill’s revenue raisers, which were themselves styled as anti-abuse and loophole-closing provisions.  As a result, we probably have not seen the last of these measures.

(more…)


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