Articles

Limited liability companies (LLC or LLCs) are an attractive choice of entity for many non-public companies. An LLC is the preferred choice of entity for many advisors, including me, unless the facts warrant something different. The preference toward...

This is the first installment of many on the topic of business owner exit planning. What is business owner exit planning? Business owner exit planning in its most basic form recognizes business owners will not operate a business forever and in many w...

For a printable PDF version of this article, please click here. For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies...

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the enhanced transfer pricing pena...

US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of significant US or foreig...

Brief commentary on the recent developments, cases, rulings, notices, and related federal tax guidance. Biden Administration Budget Proposal May Limit Tax-Free Reorganizations for Corporations with Preferred Stock Recent proposals may limit the abi...