• State and local tax due diligence: What’s the exposure?

    As the owners of a company contemplate selling, the historic state and local tax filings and activities will be a focus of a sophisticated buyer. It’s important for both the buyer and the seller to take into consideration all material state and local filing positions before concluding a sale.
  • Good news for passive foreign investment company shareholders

    The Internal Revenue Service and the Treasury Department recently issued temporary (TD 9650) and proposed (REG-140974-11) regulations providing passive foreign investment company (PFIC) guidance for tax years ending on and after Dec. 31, 2013 and, thus, applicable to 2013 calendar year taxpayers. The areas covered include determination of ownership of a PFIC, annual filing requirements, and exceptions to the filing requirements.