It is starting to look as if Congress will pass a tax bill some time in the next few days. If the currently-proposed bill is enacted, here are some of its key implications for … more

Sometimes, the best way to work with a complementary business is to acquire it (or sell one’s own business to it). Sometimes, it is a better idea to work together with it in a joint venture instead of… more

International commerce is important to all countries. Nevertheless, it can be very tempting for national governments to discriminate against foreign-owned businesses in matters of … more

States are constantly trying to find ways to get out-of-state taxpayers to comply with their tax laws. Taxpayers that do not wish to cooperate are supported by constitutional limitations on … more

When a non-U.S. person disposes of an asset having some connection to the United States, it can be difficult to determine whether the United States has a right to tax income from … more

One of the biggest potential liabilities for almost any business is wage withholding and employment taxes. Many businesses attempt to eliminate those risks by … more

Some business acquisitions involve a contingent purchase price, or “earnout,” amount that may be earned based on the business’s post-acquisition results. In order to keep the selling owners’ attention, the selling owners may be required to … more

In a couple of recent Tax Court cases, neither side’s argument was a clear winner. In one, the taxpayer failed to convince the court on a purchase price allocation; in the other, the taxpayer won on the issue of … more

Business owners and executives typically are aware of the IRS’s “responsible person” penalty that can make them personally liable if the companies they operate fail to… more

When apportioning income from services among states, the differences among the states’ income sourcing rules can create either beneficial or detrimental arbitrage. States frequently change their … more

“Nexus” is a word that describes the minimum contacts a business must have with a state in order to give the state jurisdiction to tax it. While it is clear that a business must have physical presence in a state to generate… more

The IRS and the Tax Court recently provided guidance on two issues that, while straightforward, have a tendency to cause confusion. The IRS provided clarification on ….more

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