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 … Continue reading To Minimize Taxes For Years To Come, Consider Incorporating Your Business In 2013
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 … Continue reading By Appeasing the United Kingdom, Starbucks May Have Relocated Its Tax Problems Into The United States
By: Dustin Covello Earlier this year, my former colleague Jonathan Prokup and I published an article in the Journal of Taxation and Regulation of Financial Institutions. In the article, we considered the federal tax consequences of Treasury's capital purchase program – the centerpiece of TARP. Under the program, Treasury invested several hundred billion dollars into … Continue reading TARP’s “Godfather” Investment Should Give Rise To Deductible Interest
By: Dustin Covello Late late year, we asked what's next for foreign bank account holders after OVDI? Although the answer to this question continues to evolve, it is becoming increasingly clear that the risks of detection have only grown – and will continue to do so. The latest news on this front comes from Business … Continue reading Detection Risk Continues To Grow As The IRS Expands Its Offshore Bank Account Investigation Into Liechtenstein
By Dustin Covello Editors’ note. This is the first of a new periodic series on the Tax Blawg. Mainstream press articles often implicate complex, technical tax issues. Admirably, the press attempts to simplify the tax issues to make them more interesting and digestible for the general public, but sometimes simplification can leave readers with an … Continue reading The Tax Story Behind The Big Story: The Taxation Of Carried Interests In ‘Buyout Profits Keep Flowing To Romney’
By: Jonathan Prokup & Dustin Covello After MF Global filed for bankruptcy protection just over a month ago, investigators discovered that approximately $1.2 billion of assets in customers’ accounts had somehow disappeared. Although no one at the firm has confirmed where the money went, news reports have suggested that the money may have been used … Continue reading If MF Global Lost My Money, Do I At Least Get A Tax Deduction?
By: Dustin Covello In the September 2011 issue of BNA International's Transfer Pricing Forum, Jonathan and I summarized the dispute resolution process for transfer pricing controversies against the IRS. Transfer Pricing Forum provides an overview of selected transfer pricing issues under the tax laws of twenty-five countries. For U.S. tax professionals, the publication provides … Continue reading Publication Alert: BNAI Transfer Pricing Forum