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foreign acquisitions of u.s. companies
News and Insights

Foreign Company Acquisition of U.S. Company and Need for Professionals in Each Relevant Jurisdiction

When there is a cross-border merger and acquisition there are additional complexities to plan for, typical acquisition planning in one country may be different than in another country, and the resulting tax implications can be significant. We have represented both the acquiror and target in a number of cross-border acquisitions and getting the right result requires a careful analysis of the tax implications involved. What may seem like a very small detail may have very serious tax implications that greatly impacts the result of the acquisition for either the acquiror or target.

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Mergers and Acquisitions Tax
News and Insights

Be Careful When the Terms of An Acquisition Seem Too Good to be True – They Usually Are

When there is a cross-border merger and acquisition there are additional complexities to plan for, typical acquisition planning in one country may be different than in another country, and the resulting tax implications can be significant.  We have represented both the acquiror and target in a number of cross-border acquisitions and getting the right result requires a careful analysis of the tax implications involved.  What may seem like a very small detail may have very serious tax implications that greatly impacts the result of the acquisition for either the acquiror or target.

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News and Insights

Employee Retention Credit (Employee Retention Credit Series)

The Employee Retention Credit (“ERC”) was first introduced in March 2020 to help employers retain employees through the Covid-19 pandemic.  The Internal Revenue Service (“IRS”) has made it a priority to recover wrongly claimed refunds through the ERC. 

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Tax Reminders for Target Companies in Mergers & Acquisitions
News and Insights

Target Company: Be Careful in Changing its Tax Status Preacquisition at the Insistence of the Acquiror

Target companies in mergers and acquisitions are often directed by the acquiror to change its tax classification preacquisition for U.S. tax purposes.  There are several reasons that an acquiror may request the target company to change its tax classification.  For example, the acquiror may not want an entity taxed as a c-corporation in its portfolio of companies. 

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Immediate Action to Apply for the ERC – Voluntary Disclosure Program
News and Insights

Immediate Action to Apply for the ERC – Voluntary Disclosure Program

It is important for employers who made questionable claims for the Employee Retention Credit (“ERC”) to take immediate action to determine whether the ERC Voluntary Disclosure Program (“ERC VDP”) is their best compliance option.  Since the ERC required no formal approval process other than the employer to file their employment tax returns or amended employment tax returns …

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Tax Implications of Exiting a Controlled Foreign Corporation
News and Insights

Tax Implications of Exiting a Controlled Foreign Corporation

The income of a foreign corporation is not subject to federal corporate income tax unless the foreign corporation has income that is effectively connected with a U.S. trade or business (or permanent establishment as provided in an applicable tax treaty) or consists of certain types of U.S. source fixed …

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Tax Implications of Exiting a Domestic C Corporation
News and Insights

Tax Implications of Exiting a Domestic C Corporation

Wealthy international families are choosing U.S. situs trusts over the typical offshore trust jurisdictions. In choosing a trust jurisdiction, the extremely wealthy seek the best security, most privacy, best income, lowest taxes, and lowest costs. While the extremely wealthy often utilize these trust structures, they are in no way limited to the extremely wealthy and are often used by high-net-worth individuals (i.e., more than a million in assets). For many, it is also important to diversify their asset holdings outside their country of residence. Powerful trust laws, tax savings, asset protection and privacy, as well as solutions to political and regulatory concerns, all combine to make the U.S. the trust situs of choice.

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