On April 23, 2020, the Small Business Administration (“SBA”) issued additional guidance (in an update to its previously published FAQs, a current version of which can be found here) regarding whether businesses owned by large...
Read MoreThe Tax Cuts and Jobs Act (“TCJA”) is a treasure trove of tax law changes which may (at least temporarily) reduce the tax liability of businesses. One area of tax benefit for businesses is the TCJA expansion of the expenses...
Read MoreBy: Peter J. KulickThe practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is...
Read MoreBy: Peter J. Kulick For tax attorneys, tax reform is always a hot topic. President Trump was elected with GOP majorities in both chambers of Congress, which would normally make the forecast for tax reform...
Read MoreBy Peter J. Kulick In recent years, the IRS has successfully challenged the status of many “investment” arrangements as “partnerships” for federal tax law purposes. Several of the successful challenges have centered on...
Read MoreBy Peter J. Kulick At a Departmental training session earlier this year, I explored the U.S. federal tax considerations that may arise in connection with the sale of a business. There is no “one size fits all” tax structuring...
Read MoreBy Peter J. Kulick Entities taxed as a partnership — which typically includes multi-member limited liability companies that have not elected to be treated as a corporation — are subject to specialized audit rules for...
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