Collaboration agreements, especially in the life sciences, sometimes unexpectedly transcend state boundaries, with consequences for companies’ apportionment and sales factor revenue sourcing.
The rules for qualified small business stock become more complex when it is held through a pass-through entity or when the ...
The complexities of redeeming a partner’s interest in a partnership with payments over multiple years are increased when the redeemed partner receives a promissory note.
A recent IRS letter ruling and Tax Court case illustrate, respectively, successful and unsuccessful positions regarding foreign investments in the United States as effectively connected income.
Assumptions of receivables are usually straightforward, but debt transfers can in some instances be disallowed or even be considered abusive.
Editor: Rochelle Hodes, J.D., LL.M. Employer-provided health coverage is one of the most widely relied-upon tax-favored benefits in the Internal Revenue ...
State authorities are increasingly scrutinizing companies’ escheats information regarding sourcing, dormancy tracking, and owners.
Tax-exempt hospitals should reassess how they document, report, and defend their benefit to the community to support continued exemption under Sec. 501(c)(3).
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