TAX MINIMIZATION IN MERGERS & ACQUISITIONS. Harold F. Ingersoll, CPA/ABV/CFF, CVA, CM&AA
|
|
- Gerard Flowers
- 6 years ago
- Views:
Transcription
1 TAX MINIMIZATION IN MERGERS & ACQUISITIONS Harold F. Ingersoll, CPA/ABV/CFF, CVA, CM&AA
2 Stock/Interest Asset
3 Reason is to transfer nonassignable contracts and liabilities Can be treated like an asset deal, Sec. 338 (h)(10) for C Corps and Sec. 336(e) for S Corps. If election is made, then options are the same as the asset deal. (Discussed later.)
4 C Corporations Only Avoid taxes using Sec If Qualifying Small Business Stock (QSBS) Exclusion of gain up to $10m. Some reductions if original stock purchased before 2/17/2009. QSBS must have always been taxed as a C Corporation (could never have been anything else). Stock held must be original issue stock. Assets cannot exceed $50m. Must hold original stock for 5 years or more. Defer taxes using Sec If Qualifying Small Business Stock (QSBS) Unlimited amount of gain can be deferred. Must be rolled over into another QSBS within 60 days of sale. Must have held the QSBS only 6 months prior to sale.
5 All Corporations (C&S) Defer taxes Reorganization/Mergers: Forward or reverse triangular mergers Other merger types If outright sale by individual, profit is capital gains ( Usually no Texas Franchise taxes )
6 Partnerships and LLCs Interest sale Capital gains to selling partners on all except Hot Assets. Hot assets are primarily accounts receivable and inventory, these may be taxed as ordinary income. Taxes can be deferred if Section 721 is used. ( Usually no Texas Franchise taxes )
7 Reason is to leave seller liabilities with the seller. Usually, all assets (except cash) and potentially accounts receivable & accounts payable. Buyer may assume some specific liabilities. Gain taxation depends on allocation of purchase price to specific asset classes. Type of entity makes a huge difference.
8 C Corporations All gains recognized are taxed at ordinary income tax rates regardless of the character (capital/ordinary). To get funds out of the corporation, the shareholders receive a bonus or taxable dividend. If the gains are too large, bonuses become difficult due to reasonable compensation issues. If dividend, it is double taxed. Maximum rate at corporation is 35%, then at individual level is 23.8%, total maximum rate of 58.8% if paid out as dividend. If there is significant personal goodwill owned by the selling shareholder which can be justified, the buyer can purchase the personal goodwill directly from the seller. This creates capital gains for the seller outside of the corporation that are taxed at maximum rate of 23.8%.
9 S Corporations & Partnerships Gains depend on how the purchase price is allocated: Seller motivated to allocate more to intangibles, such as goodwill, which will be taxed as capital gains. Buyer motivated to allocate as much to tangible assets (furniture, equipment, etc ) as possible to get quicker tax write off. Good news is even intangibles get the tax benefit. It just takes 15 years to get the benefit. If proceeds need to be allocated disproportionately or contrary to allocation protocol, they can be directed outside of the entity directly to the owners for their personal goodwill, if it can be justified. Taxes are the same, but are proceeds are directed to different owners.
10 C CORPORATION: Gain $1,000,000 Corporate tax None Individual tax: If 1202 None on potentially first $10m If 1045 Potentially none If neither $238,000 S CORPORATION: Gain $1,000,000 Corporate tax None Individual tax: If merger None on amount swapped for buyer stock If neither $238,000 (Does not take AMT into consideration)
11 PARTNERSHIP: Gain $1,000,000 Individual tax: If merger None on amount swapped for buyer int. If neither $238,000 (Does not take AMT into consideration)
12 C CORPORATION: Gain $1,000,000 Corporate tax: Franchise tax $ 7,500 Income tax $ 350,000 Individual tax: If dividend paid of $650k $ 154,000 Total taxes $ 511,500 S CORPORATION: Gain $1,000,000 Corporate : Texas Franchise Tax $ 7,500 Income tax None (if never been a C corp) Individual tax: $ 238,000 Total taxes $ 245,500 (Does not take AMT into consideration)
13 PARTNERSHIP: Gain $1,000,000 Franchise tax $ 7,500 Individual tax: $ 238,000 Total taxes $ 245,500 (Does not take AMT into consideration)
14 1. If entity is a C Corporation consult with someone about the qualification for Sec and 1045 to see if qualified. If so, consider the possibilities of a stock deal in a future sale. If a stock deal is not likely, then consider making an S election. If S election made, in 5 years the gain on any sale will be taxed as an asset deal from an S corporation, avoiding double tax on all gains in excess of remaining C Corporation Earnings and Profits.
15 2. When structuring a new business consider the possible exit strategies before selecting an entity type. If likely to be a stock/interest deal, then consider being a C Corporation from the start so as to qualify for Sec and If more likely to be an asset deal then consider S Corporation or Partnership/LLC structure. Partnership/LLC offers more flexibility in ownership structure than an S Corporation. Venture capital, angel and private equity investors are becoming more accepting of pass through entities in acquisitions.
16 3. When structuring ownership of intellectual property, goodwill, real estate, and other tangible assets, plan the most effective manner of holding the property. Will IP be held in a separate entity and then licensed to the operating entity and a royalty be paid? This way IP can be licensed to others without impairing the value of the operating entity or the IP. Will the company execute non-compete agreements with the shareholder/employees? If so, they are creating more value for the company, but reducing the possibility of allocating purchase price to personal goodwill of the owners, thus minimizing tax planning opportunities in structuring a future deal. Will real estate owned by the company be attractive to a potential buyer? If potentially not, consider placing in a separate entity and charge rent to the operating entity. This will facilitate the better possibility of negotiating a stock or interest deal when sale time comes. Will equipment or other fixed assets be owned by the company or a separate company and leased back to the operating company? This may be attractive to segregate liability associated with heavy equipment and may facilitate a stock/interest deal in the future for a buyer that does not want the equipment.
17 This is a very complicated area of the law and requires knowing the market place in which the company is operating and planning for it. The market changes continually, so the planning needs to change also.
18 Many of the issues discussed in this presentation have significant legal impact in addition to income tax impact. I am not an attorney and any discussion of liability or legal structure issues need to be discussed with an attorney prior to decision making.
19 Any EASY questions?
20 Harold Ingersoll, Partner, CPA/ABV/CFF, CVA, CM&AA Atchley & Associates, LLP 1005 La Posada Drive Austin, Texas (512) ; (512) fax
FEDERAL INCOME TAX CONSIDERATIONS IN ACQUISITIONS AND DISPOSITIONS OF S CORPORATIONS
FEDERAL INCOME TAX CONSIDERATIONS IN ACQUISITIONS AND DISPOSITIONS OF S CORPORATIONS The University of Texas School of Law 60 th Annual Taxation Conference Timothy J. Devetski Lina G. Dimachkieh Vinson
More informationEquity-Based Compensation What Issues Do We Need to Consider?
BishopDulaneyJoyner&Abner Equity-Based Compensation What Issues Do We Need to Consider? by J. Dain Dulaney Jr., Attorney J. Dain Dulaney, Jr., Attorney ddulaney@bdjalaw.com v Dain s practice focuses on
More informationCommon Financial Terms and What They Really Mean
Common Financial Terms and What They Really Mean Sherri S. Holder, CPA/ABV/CFF, CVA 770.579.3860 sherri.holder@thgcpa.net Topics we will cover 1. Income v. Distributions 2. Retained Earnings 3. Book Value
More informationAs at March 31, 2016 As at April 1, 2015 Balance Sheet as at March 31, 2017 Note No. Rs. Lakhs Rs. Lakhs Rs. Lakhs Rs. Lakhs
As at March 31, 2017 As at March 31, 2016 As at April 1, 2015 Balance Sheet as at March 31, 2017 Note No. ASSETS Non-current assets Property, plant and equipment 1.1-0.02 10.34 Capital work-in-progress
More informationTax Considerations in M&A Transactions. Anthony R. Boggs, Esq. Morris, Manning & Martin, LLP
Tax Considerations in M&A Transactions Anthony R. Boggs, Esq. Morris, Manning & Martin, LLP Diagram Legend C corp for U.S. federal income tax purposes Partnership for U.S. federal income tax purposes S
More informationTax Considerations in Choosing the Form of Organization for a New Business
Tax Considerations in Choosing the Form of Organization for a New Business By Charles A. Wry, Jr. mbbp.com @MorseBarnes Boston, MA Cambridge, MA Waltham, MA mbbp.com CityPoint 230 Third Avenue, 4th Floor
More informationMergers & Acquisitions After Tax Reform
I. Background Mergers & Acquisitions After Tax Reform Robert J. Bauer, CPA, Dopkins & Company, LLP Kelly E. Marks, Esq., Phillips Lytle LLP Gregory J. Urban, CPA, CVA, Dopkins & Company, LLP A. The Tax
More informationAcc. 433, Chapter Outline for use with Prentice Hall's Federal Taxation Corporations Richard B. Malamud, last updates, in part, November, 2011
Acc. 433, Chapter Outline for use with Prentice Hall's Federal Taxation Corporations Richard B. Malamud, last updates, in part, November, 2011 1) Chapter 1 was not assigned! 2) Formation and Capital Structure
More informationTexas Franchise Tax. Internal Revenue Code Capital of Texas Enrolled Agents Conference November 13, 2012 Austin, Texas
Texas Franchise Tax and the Internal Revenue Code Capital of Texas Enrolled Agents Conference November 13, 2012 Austin, Texas Presented by: Janet Spies Texas Tax Training & Consulting Overview IRC References
More information5. Consolidated Financial Statements (1) Consolidated Balance Sheets
5. Consolidated Financial Statements (1) Consolidated Balance Sheets March 31, 2008 Assets Current assets Cash and deposits 84,224 89,218 Notes and accounts receivable-trade 230,156 234,862 Lease receivables
More informationTax Issues in Sale of Partnership and LLC Interests. November 3, MACPA: 2014 Advanced Tax Institute Conference
Tax Issues in Sale of Partnership and LLC Interests November 3, 2014--MACPA: 2014 Advanced Tax Institute Conference Outline Tax Classification of Partnerships and LLCs Tax Consequences in General to Seller
More informationMACNY. Tax Implications of a Business Transaction. May 10, 2017
MACNY Tax Implications of a Business Transaction May 10, 2017 Thomas J. Giufre Fust Charles Chambers LLP Review of the Different Types of Entities C Corporation: Entity level taxation Two levels of taxation
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Choice of Entity Under the New Tax Law: Avoiding Tax Pitfalls in Operations, Ownership Changes, Exit Strategies Capital vs. Profits Interest, Allowable
More informationTax planning for U.S. business operations of Indian enterprises
D:\ALL DATA OF ANIL\ANIL\IT MAG 2011\IT FROM JANUARY 2011\IT V5P5 (NOVEMBER 2011)\IT V5P5-ART 3 (TOPICS) MAK\CORR 24-10-2011/2-11-2011 70 USA- TAX PLANNING FOR INDIAN ENTERPRISES Tax planning for U.S.
More informationTax Guide For Minnesota Businesses
Tax Guide For Minnesota Businesses 2017-2018 TAX GUIDE FOR MINNESOTA BUSINESSES Olsen Thielen & Co., Ltd. Certified Public Accountants & Consultants 2675 Long Lake Road 300 Prairie Center Drive #300 Roseville,
More informationGroup Consolidated Income Statement
Group Consolidated Income Statement Pre- Exceptional Pre- Exceptional Exceptional (Note 2) Total Exceptional (Note 2) Total 2018 2018 2018 2017 2017 2017 Note m m m m m m Group revenue 1 739.3-739.3 701.3-701.3
More informationComing to America. U.S. Tax Planning for Foreign-Owned U.S. Operations. By Len Schneidman. Andersen Tax LLC, U.S.
Coming to America U.S. Tax Planning for Foreign-Owned U.S. Operations By Len Schneidman Andersen Tax LLC, U.S. June 2017 Table of Contents Introduction... 2 Tax Checklist for Foreign-Owned U.S. Operations...
More informationConsolidated Financial Statements (1) Consolidated Balance Sheets
Consolidated Financial Statements (1) Consolidated Balance Sheets End of consolidated (as of End of consolidated (as of Assets Current assets Cash and time deposits 25,726 34,157 Notes and accounts receivable
More informationFINANCIAL RESULTS. Consolidated Financial Statements - Fiscal Year Ended March 31, Consolidated Balance Sheets
FINANCIAL RESULTS Consolidated Financial Statements - Fiscal Year Ended March 31, 2007-1. Consolidated Balance Sheets (ASSETS) Prior Year End Current Year End (As of March 31, 2006) (As of March 31, 2007)
More informationROADMAP FROM CONCEPT TO IPO.
The ENTREPRENEUR S ROADMAP FROM CONCEPT TO IPO www.nyse.com/entrepreneur Download the electronic version of the guide at: www.nyse.com/entrepreneur 41 EXITING THE BUSINESS: WHAT ARE THE TAX IMPLICATIONS?
More informationImplications of the 2017 Tax Act: Choice of Entity
Implications of the 2017 Tax Act: Choice of Entity January 25, 2018: Bruce Booken, Buchanan Ingersoll & Rooney Lisa Starczewski, Buchanan Ingersoll & Rooney Samuel Starr, Bloomberg BNA 1 The 2017 Tax Act
More informationFinancial Results For the Fiscal Year 2016 ending January 31, 2016
Financial Results For the Fiscal Year 2016 ending January 31, 2016 March 16, 2016 Balance Sheets (Consolidated) Thousands of Yen 31 Jan., 2016 Assets Current assets: Cash & Cash equivalents 1,984,469 Accounts
More informationRent Payments vs. Installment Purchases
Rent Payments vs. Installment Purchases If a business rents anything necessary for the business, such as an office, a copier, machinery, etc., 100% of the rent can usually be deducted as an ordinary business
More informationInternet Disclosure of Matters for the Notice of the 9th Ordinary General Shareholders Meeting. Notes to the Consolidated Financial Statements 1
Internet Disclosure of Matters for the Notice of the 9th Ordinary General Shareholders Meeting Notes to the Consolidated Financial Statements 1 Notes to the Non-consolidated Financial Statements 16 In
More informationBusiness Valuation. Table of Contents. Why Do You Need to Know the Value of Your Business? 2. What Is the Value of Your Business?
Business Valuation Since there generally is not a ready market for the sale of a closely-held business interest, a business valuation method is frequently used to determine the value of the business...a
More informationImpact of Tax Reform on Choice of Entity and M&A Transactions
Impact of Tax Reform on Choice of Entity and M&A Transactions Kieran Coe Tim Smith February 27, 2018 Overview of topics Key federal income tax rate changes Choice of entity considerations Converting to
More information- Definition - Qualitative and Quantitative IP Valuation
Basics on Intellectual Property Valuation - Definition - Qualitative and Quantitative IP Valuation Tehran December 11, 2017 Christopher M. Kalanje Counsellor, SMEs and Entrepreneurship Support Division,
More informationOil and Gas Tax Issues. Don Nestor, CPA Ryan Nestor, CPA, CGMA Bill Phillips, CPA J. Marlin Witt, CPA, CFP
Oil and Gas Tax Issues Don Nestor, CPA Ryan Nestor, CPA, CGMA Bill Phillips, CPA J. Marlin Witt, CPA, CFP Arnett Carbis Toothman llp 2018 Depletion and Ways to Compute What is depletion and what is its
More informationRay Sigorta Anonim Şirketi Balance Sheet As At 30 June 2016 (Currency: Turkish Lira (TL))
Balance Sheet ASSETS Current Period 30 June 2016 Audited 31 December 2015 I- Current Assets A- Cash and Cash Equivalents 280.951.812 226.401.451 1- Cash 53.648 45.712 2- Cheques Received 12 12 3- Banks
More informationCircumstances in Which an IRA May Owe Taxes 1
Circumstances in Which an IRA May Owe Taxes 1 By: H. Quincy Long, Phone: 281-492-3434 Attorney and President of Fax: 281-646-9701 Entrust Retirement Services, Inc. Toll-Free: 800-320-5950 17171 Park Row,
More informationANALYZING POTENTIAL OWNERSHIP TRANSITION OPTIONS UTILIZING DEFERRED COMPENSATION ARRANGEMENTS
ANALYZING POTENTIAL OWNERSHIP TRANSITION OPTIONS UTILIZING DEFERRED COMPENSATION ARRANGEMENTS by Ronald J. Adams, CPA, CVA, ABV, CBA, CFF, FVS, CGMA Many smaller companies want to share ownership with
More informationCorporate Taxation Chapter Eight: Taxable Acquisitions
Presentation: Corporate Taxation Chapter Eight: Taxable Acquisitions Professors Wells March 9, 2015 Chapter 8 Taxable Corporate Acquisitions/Dispositions Corporate ownership disposition options: 1) Sale
More informationConsolidated Financial Statements (1) Consolidated Balance Sheet
Consolidated Financial Statements (1) Consolidated Balance Sheet As of March As of March Assets Current assets Cash and deposits 18,229 18,673 Notes and accounts receivable - trade 24,077 25,891 Merchandise
More informationFUJI YAKUHIN CO., Ltd. Consolidated Financial Statements For the Year ended March 31,2017
FUJI YAKUHIN CO., Ltd. Consolidated Financial Statements For the Year ended March 31,2017 CONSOLIDATED BALANCE SHEET As of March 31,2017 ASSETS Current assets: Cash and deposits 7,156 $ 63,792 Notes and
More informationBuild Up the Bucks! How to Structure the Sale of a Client's Business to Increase the Cash Flow
Build Up the Bucks! How to Structure the Sale of a Client's Business to Increase the Cash Flow Dr. Bart A. Basi CPA / Attorney at Law Senior Advisor The Center for Financial, Legal & Tax Planning, Inc.
More informationLLC OR CORP - AFTER THE PROPOSED SECTION 199A REGULATIONS - CASE STUDIES. Presenters:
LLC OR CORP - AFTER THE PROPOSED SECTION 199A REGULATIONS - CASE STUDIES Presenters: William C. Staley, Attorney LAW OFFICE OF WILLIAM C. STALEY www.staleylaw.com 818-936-3490 Megan Lisa Jones, Attorney
More informationIncorporating Your Startup: Choice of Entity and Tax Considerations
Incorporating Your Startup: Choice of Entity and Tax Considerations Presentation to Boston ENET December 6, 2011 Mark A. Haddad Partner 617-832-1724 mhaddad@foleyhoag.com www.emergingenterprisecenter.com
More informationSTATE AND LOCAL TAX IPT ANNUAL CONFERENCE. Eran Liron. Arthur J. Parham
STATE AND LOCAL IPT ANNUAL CONFERENCE TAX Eran Liron State and Local Tax Partner PricewaterhouseCoopers, LLP San Jose, CA Eran.J.Liron@us.pwc.com Arthur J. Parham General Tax Advisor Entergy Services,
More informationSCR Reporting. Checklist Key areas requiring
Checklist Key areas requiring attention This checklist is designed to assist users to identify the potential changes introduced by FRS 102 Section 1A, and to outline the accounting policy and transitional
More informationTax Considerations in Buying or Selling a Business
Tax Considerations in Buying or Selling a Business By Charles A. Wry, Jr. @MorseBarnes Boston, MA Cambridge, MA Waltham, MA mbbp.com This article is not intended to constitute legal or tax advice and cannot
More informationComing to America. U.S. Tax Planning for Foreign-Owned U.S. Operations. By Len Schneidman. Andersen Tax LLC, U.S.
Coming to America U.S. Tax Planning for Foreign-Owned U.S. Operations By Len Schneidman Andersen Tax LLC, U.S. January 2018 Table of Contents Introduction... 2 Tax Checklist for Foreign-Owned U.S. Operations...
More informationBELGIUM GLOBAL GUIDE TO M&A TAX: 2018 EDITION
BELGIUM 1 BELGIUM INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? A major corporate income tax reform has been published
More informationAdvanced Tax Issues in Entity Selection Choosing the Entity to Meet the Client's Business Strategies and Capital and Compensation Structures
Presenting a live 90 minute webinar with interactive Q&A Advanced Tax Issues in Entity Selection Choosing the Entity to Meet the Client's Business Strategies and Capital and Compensation Structures TUESDAY,
More informationEffective Tax Planning For Partnerships:
When used properly, an IRC 754 election can be an important tool for an estate planning or business planning attorney. It can make a big difference in the tax burden of a company s partners and should
More informationInternet Disclosure of Matters for the Notice of the 10th Ordinary General Shareholders Meeting. Notes to the Consolidated Financial Statements 1
Internet Disclosure of Matters for the Notice of the 10th Ordinary General Shareholders Meeting Notes to the Consolidated Financial Statements 1 Notes to the Non-consolidated Financial Statements 15 In
More informationASSETS As of March 31, 2014 (000's Except shares and per share amounts)
Exhibit 99.3 UNAUDITED PRO FORMA CONDENSED CONSOLIDATED FINANCIAL STATEMENTS ASSETS As of March 31, 2014 (000's Except shares and per share amounts) GPS SecureAlert Global Adjustments Consolidated CURRENT
More informationSwiss GAAP FER 2017 Checklist for application and disclosure. Audit & Assurance
Swiss GAAP FER 2017 Checklist for application and disclosure Audit & Assurance Foreword This checklist shall support in applying the Swiss GAAP FER standards as well as in reviewing the completeness of
More informationBERMUDA ECONOMIC SUBSTANCE AMENDMENT REGULATIONS 2019 BR 34 / 2019
QUO FA T A F U E R N T BERMUDA BR 34 / 2019 TABLE OF CONTENTS 1 2 3 4 5 6 7 8 Citation Amends regulation 2 Amends regulation 3 Amends regulation 4 Amends regulation 5 Revokes and replaces regulation 14
More informationSwiss GAAP FER 2017 Checklist for application and disclosure. Audit & Assurance
Swiss GAAP FER 2017 Checklist for application and disclosure Audit & Assurance Foreword This checklist shall support in applying the Swiss GAAP FER standards as well as in reviewing the completeness of
More informationSEMINAR ON TRANSFER PRICING 23rd September, Valuation Approaches and their applicability under Transfer Pricing. CA Siddharth Banwat
SEMINAR ON TRANSFER PRICING 23rd September, 2017 Valuation Approaches and their applicability under Transfer Pricing WHAT IS VALUATION? WHAT IS VALUE? A value in exchange is a hypothetical price and the
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Denmark General Denmark 1. What are recent tax developments in your country which are relevant for M&A deals? During the past year, the Danish Parliament adopted new legislation in a number of different
More informationMillî Reasürans Türk Anonim Şirketi Unconsolidated Balance Sheet As At 30 September 2018 (Currency: Turkish Lira (TL))
Unconsolidated Balance Sheet As At ASSETS 1 Audited 31 December 2017 I- Current Assets A- Cash and Cash Equivalents 4.2,14 1.654.893.371 1.223.132.413 1- Cash 4.2,14 58.270 5.842 2- Cheques Received 3-
More informationONLINE VACATION CENTER HOLDINGS CORP. CONSOLIDATED FINANCIAL STATEMENTS December 31, 2017 and 2016
ONLINE VACATION CENTER HOLDINGS CORP. CONSOLIDATED FINANCIAL STATEMENTS December 31, 2017 and 2016 Fort Lauderdale, Florida CONSOLIDATED FINANCIAL STATEMENTS December 31, 2017 and 2016 CONTENTS INDEPENDENT
More informationExecutive Breakfast Briefing Accounting & Taxes in the New Year. Sensiba San Filippo LLP 1
Executive Breakfast Briefing Accounting & Taxes in the New Year Sensiba San Filippo LLP www.ssfllp.com 1 Significant Accounting Standards Updates Sensiba San Filippo LLP www.ssfllp.com 2 Private Company
More informationDay 1 October 21, 2015:
BUSINESS PLANNING WITH S CORPS, PART 1 & PART 2 First Run Broadcast: October 21 & 22, 2015 1:00 p.m. E.T./12:00 p.m. C.T./11:00 a.m. M.T./10:00 a.m. P.T. (60 minutes each day) This program will provide
More informationCheckpoint Learning (courses available in various media formats)
Course Title Field of Study 2012 FASB Update Accountant's Overview of Financial Management and Auditing Real Estate Transactions and Financial Reporting Developments Changes and Error Corrections for Investments:
More informationTAX REFORM Speakers: Brian Dethrow and Ron Kerridge
TAX REFORM Speakers: Brian Dethrow and Ron Kerridge Estate Planning Council of Central Texas CLE February 6, 2018 Jackson Walker L.L.P. 2018 C Corporations The Hottest Tax Shelter Jackson Walker L.L.P.
More informationCHAPTER 10 COMPARATIVE FORMS OF DOING BUSINESS LECTURE NOTES
CHAPTER 10 COMPARATIVE FORMS OF DOING BUSINESS 10.1 FORMS OF DOING BUSINESS LECTURE NOTES 1. Legal Forms. Business entities can be organized into the following principal legal forms. Sole proprietorship.
More informationPresenting a live 90-minute webinar with interactive Q&A. Today s faculty features:
Presenting a live 90-minute webinar with interactive Q&A Goodwill in Corporate Asset Sales: Tax Planning Opportunities Distinguishing Between Personal and Corporate Goodwill, Navigating Allocation and
More informationDon t Let 2018 Be Taxing:
Don t Let 2018 Be Taxing: How Changes to the Tax Laws Change How We Counsel Businesses March 15, 2018 Agenda Introduction C corporation overview Pass-through overview Comparison 2 Introduction Types of
More informationALI-ABA Course of Study Going International: Fundamentals of International Business Transactions. December 7-9, 2006 Washington, D.C.
215 ALI-ABA Course of Study Going International: December 7-9, 2006 Washington, D.C. Presentation Slides By, Esquire Baker & McKenzie LLP Chicago, Illinois 216 2 217 Fundamentals of International Business
More informationUS Taxation- A Primer
WIRC of the ICAI- Seminar Series on Global Updates- I US Taxation- A Primer Presented by : 7 th May, 2011 CA. Shishir Lagu Session Overview Introduction Corporate Tax Overview Federal Income Tax State
More informationMURATA MACHINERY, LTD.
(English Translation) AUDITED FINANCIAL STATEMENTS FOR THE YEAR ENDED MARCH 31, 2018 1. Consolidated balance sheets 2. Consolidated statement of operations 3. Non-consolidated balance sheets 4. Non-consolidated
More informationRental Real Estate Deductions
Rental Real Estate Deductions 15 th Edition Stephen Fishman, J.D. Chapter 1 Tax Deduction Basics for Landlords... 1 Learning Objectives... 1 Introduction... 1 How Landlords Are Taxed... 1 Income Taxes
More informationMillî Reasürans Türk Anonim Şirketi Unconsolidated Balance Sheet As At 30 June 2018 (Currency: Turkish Lira (TL))
Unconsolidated Balance Sheet As At ASSETS. 1 31 December 2017 I- Current Assets A- Cash and Cash Equivalents 4.2,14 1.237.184.185 1.223.132.413 1- Cash 4.2,14 52.698 5.842 2- Cheques Received 3- Banks
More informationOpportunity Zones A Few Open Issues
Opportunity Zones A Few Open Issues, Nixon Peabody, LLP, Boston, MA, Applegate & Thorne-Thomsen, Chicago, IL, Novogradac, Boston, MA NH&RA, Martha s Vineyard, July 20, 2018 What Taxpayer must do the investing,
More informationSection 6 Depreciation (Cost Recovery)
Section 6 Depreciation (Cost Recovery) Federal tax law uses Modified Accelerated Cost Recovery System (MACRS; tax treatment) which is different from GAAP depreciation (financial accounting; book purpose).
More informationPeriod Ending: 03/31/ /31/2015
Balance Sheet Assets Current assets Cash and deposits 1,798,992 1,989,414 Notes and accounts receivable - trade 871,418 1,052,104 Electronically recorded monetary claims - operating 25,052 58,320 Securities
More informationMillî Reasürans Türk Anonim Şirketi Consolidated Balance Sheet As At 30 September 2017 (Currency: Turkish Lira (TL))
Consolidated Balance Sheet As At ASSETS Restated Audited 31 December 2016 I- Current Assets A- Cash and Cash Equivalents 14 4.776.447.134 4.342.688.861 1- Cash 14 81.993 52.555 2- Cheques Received 450.000
More informationTax FAQs for US Inbound Transactions
Tax FAQs for US Inbound Transactions By Robert M. Finkel and Diana C. Española mbbp.com Corporate IP Licensing & Strategic Alliances Employment & Immigration Taxation Litigation 781-622-5930 3 Tax FAQs
More informationPRIVATE EQUITY FUND AND PORTFOLIO COMPANIES: THE IMPACT OF TAX REFORM
PRIVATE EQUITY FUND AND PORTFOLIO COMPANIES: THE IMPACT OF TAX REFORM Jan. 23, 2018 Authors Nick Gruidl, Partner Gennaro Musi, Partner Michael Nader, Partner 1 The Tax Cuts and Jobs Act (TCJA) was signed
More informationDEMYSTIFYING GIFTS INVOLVING LLCS MPGC 39 TH ANNUAL CONFERENCE. Selected Forms of Business Organization By U.S. Tax Return Filed
DEMYSTIFYING GIFTS INVOLVING LLCS MPGC 39 TH ANNUAL CONFERENCE Mark Ladendorf Senior Relationship Manager Bill Knox Director, Planned Gift Technical Consulting Selected Forms of Business Organization By
More informationFORMALIZING YOUR FIRM: LLC VERSUS S CORPORATION VERSUS C CORPORATION
better choice for your business. The following is a discussion of the differences that most typically impact our clients. FORMALIZING YOUR FIRM: LLC VERSUS S CORPORATION VERSUS C CORPORATION by Stephanie
More informationCOMPARISON OF BUSINESS ENTITIES
COMPARISON OF BUSINESS ENTITIES Applicable Factor C Corporation S Corporation Sole Proprietor Partnership I. Formation A. Method Articles of Incorporation Articles of Incorporation None Partnership Agreement
More information3. CONSOLIDATED QUARTERLY FINANCIAL STATEMENTS
3. CONSOLIDATED QUARTERLY FINANCIAL STATEMENTS (1) Consolidated Quarterly Balance Sheets September 30, 2013 and March 31, 2013 March 31, 2013 September 30, 2013 Assets Current assets Cash and deposits
More informationSmall Business Management MGMT5601 Workshop 5 Part A: Acquisition or Exit
Small Business Management MGMT5601 Workshop 5 Part A: Acquisition or Exit Professor Tim Mazzarol UWA Business School SBM MGMTG5601 UWA Business School MBA Program tim.mazzarol@uwa.edu.au Mazzarol 2018
More informationLegal Issues in Organizing your Business
Legal Issues in Organizing your Business USAC National Conference November 1, 2014 Dave Steigerwald Business Organization Drivers Liability Protection Tax Efficiency Business Goals Liability Protection
More informationFAIR MARKET VALUE APPRAISAL
FAIR MARKET VALUE APPRAISAL Subject Company: Sample Company Heating & Air Subject Interest: 100% ownership interest Date of Appraisal: November 30, 2016 Date of Report: December 8, 2016 Page 1 of 1 December
More informationAccounting for Business Decisions B
Accounting for Business Decisions B Non-current assets Describe non-current assets and how they are recorded, expensed, and reported Resource that is expected to be used in the normal course of operations
More informationPuerto Rico Tax Compliance Guide By: Torres CPA Group (TCG) & CifrasPR
Puerto Rico Tax Compliance Guide By: Torres CPA Group (TCG) & CifrasPR Understanding the Puerto Rico tax system and its interrelation with United States is crucial for individuals and entities doing business
More informationIFRS Interim Results. 25 weeks to 24 July November 2005
IFRS Interim Results 25 weeks to 24 July 2005 17 November 2005 Overview 2 UK GAAP trading update of 20 October remains unchanged Operating profit before exceptionals unchanged at 50.7m Conversion to IFRS
More informationTax Cuts & Jobs Act: Considerations for M&A
A LERT M EM OR A N D UM Tax Cuts & Jobs Act: Considerations for M&A January 17, 2018 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts & Jobs
More informationTax Considerations in Buying or Selling a Business
Tax Considerations in Buying or Selling a Business By Charles A. Wry, Jr. mbbp.com Corporate IP Licensing & Strategic Alliances Employment & Immigration Taxation 781-622-5930 CityPoint 230 Third Avenue,
More informationAmended and restated consolidated financial statements of MTY Food Group Inc. November 30, 2016 and 2015
Amended and restated consolidated financial statements of MTY Food Group Inc. November 30, 2016 and 2015 Deloitte LLP La Tour Deloitte 1190 Avenue des Canadiens-de-Montréal Suite 500 Montreal QC H3B 0M7
More informationHalf-yearly financial statements 30 June Quantum Genomics
Half-yearly financial statements 30 June 2018 30/06/2018 Interim Balance sheet Assets Registered Number : 48799664700029 Fixed assets Current assets Intangible fixed assets Tangible fixed assets Financial
More informationSTRUCTURING REAL ESTATE PARTNERSHIP/LLC DIVORCES
STRUCTURING REAL ESTATE PARTNERSHIP/LLC DIVORCES Breaking Up Is Not Always So Hard To Do Maryland Advanced Tax Institute Brian J. O Connor Norman Lencz November 21, 2013 CASE STUDY A and B, unrelated individual
More informationIAS Primary Financial Statements (PFS), Financial Reporting for Commercial and Industrial Enterprises,
1 iascf-pfs Primary Financial Statements (abstract) (iascf-pfs:iascf.pfs) IAS 1 2 0 iascf-pfs Balance Sheet (abstract) (iascf-pfs:bst) IAS 1 53; IAS 1 7 a 3 0 debit Monetary iascf-pfs Assets (iascf-pfs:ast)
More informationMotives and Innovative ways of Structuring and Accounting for Business combination
Motives and Innovative ways of Structuring and Accounting for Business combination Presenter: Amrish Shah January 20, 2017 *Intended for general guidance only Content Modes of M&A in India Indian laws
More informationShindengen Electric Manufacturing Co., Ltd.
Consolidated Financial Highlights FY2013 FY2014 FY2015 FY2016 FY2017 Net sales 104,564 108,255 98,110 92,688 92,177 Operating profit 11,313 7,673 799 5,238 6,853 Ordinary profit 10,960 7,861 405 4,739
More informationConsolidated financial statements of MTY Food Group Inc. November 30, 2016 and 2015
Consolidated financial statements of MTY Food Group Inc. November 30, 2016 and 2015 Deloitte LLP La Tour Deloitte 1190 Avenue des Canadiens-de-Montréal Suite 500 Montreal QC H3B 0M7 Canada Tel: 514-393-7115
More information23 rd Annual Health Sciences Tax Conference
23 rd Annual Health Sciences Tax Conference December 11, 2013 Disclaimer Any US tax advice contained herein was not intended or written to be used, and cannot be used, for the purpose of avoiding penalties
More informationJoint Ventures and Strategic Alliances: Key Considerations for Negotiation, Structuring & Drafting Terri Krivosha Maslon LLP
Joint Ventures and Strategic Alliances: Key Considerations for Negotiation, Structuring & Drafting Terri Krivosha Maslon LLP 1. What is a Joint Venture or Strategic Alliance? a. A relationship between
More informationDocuments Glossary of IP Terms/Financial
Documents Glossary of IP Terms/Financial ABATNA (Best Alternative to a Negotiated Agreement). Any negotiator should determine his or her BATNA before agreeing to any negotiated settlement. If the alternative
More informationANADOLU ANONİM TÜRK SİGORTA ŞİRKETİ DETAILED BALANCE SHEET. ASSETS I- Current Assets
ASSETS I- Current Assets A- Cash and Cash Equivalents 14 3.775.262.937 3.504.676.959 1- Cash 14 54.840 62.857 2- Cheques Received 3- Banks 14 3.388.494.332 3.105.334.647 4- Cheques Given and Payment Orders
More informationANADOLU ANONİM TÜRK SİGORTA ŞİRKETİ DETAILED BALANCE SHEET ASSETS
ASSETS I- Current Assets A- Cash and Cash Equivalents 14 3.815.809.477 3.504.676.959 1- Cash 14 45.563 62.857 2- Cheques Received - - 3- Banks 14 3.402.899.507 3.105.334.647 4- Cheques Given and Payment
More informationHow to Get Your Nonprofit Back in Good Standing
How to Get Your Nonprofit Back in Good Standing Texas nonprofits are subject to numerous complicated laws and regulations, filing and reporting requirements. Failure to comply with these requirements can
More informationFundamentals of International Business Transactions
20 th Annual ALI-ABA Course of Study Fundamentals of International Business Transactions Part 2 Introduction to International Taxation Robert J. Cunningham Baker & McKenzie International is a Swiss Verein
More informationTax Cuts & Jobs Act: Considerations for Funds
A LERT M EM OR A N D UM Tax Cuts & Jobs Act: Considerations for Funds January 25, 2018 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts &
More informationEmirates Integrated Telecommunications Company PJSC and its subsidiaries
Emirates Integrated Telecommunications Company PJSC and its subsidiaries Condensed interim consolidated financial statements for the nine-month period ended 2015 Emirates Integrated Telecommunications
More informationSmall Business Valuation Overview and Analysis
Small Business Valuation Overview and Analysis presented by Tim Mezhlumov, EA, CFP, CLU Business Valuation - Definition The process of determining the economic value or Fair Market Value (FMV) of a company
More information