A redemption of stock owned by a shareholder of a corporation may be characterized as a “sale or exchange” under IRC Section 302 or as a “dividend” payment under IRC Section 301. The manner in which the redemption is...
Read MoreA “net operating loss” (“NOL”) arises when the amount of a taxpayer’s business deductions for the current tax year exceed its gross income for the current tax. Prior to the enactment of the 2017 Tax Cuts and Jobs Act (generally...
Read MoreWhen a taxpayer purchases an interest in a partnership (or membership interest in an LLC taxed as a partnership) owning appreciated assets, the taxpayer may able to obtain a step-up in his, her or its share of the partnership’s...
Read MoreBy: Troy TerakedisA buyer of a business often will prefer to purchase assets rather than equity interests in order to, among other things, obtain a step-up in the tax basis of the assets of the business equal to its purchase...
Read MoreBy J. Troy Terakedis & Brian K. Kim A taxpayer who is considering the sale of certain stock may have the opportunity to exclude or defer part or all of the gain on such sale. To be eligible for the exclusion or deferral,...
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