Business & Tax Blog

The Canada Revenue Agency (“CRA”) announced at the May 26 meeting of the International Fiscal Association in Montreal that limited liability limited partnerships and limited liability partnerships organized under the laws of Florida or Delaware will be taxable as corporations for Canadian income tax purposes. The CRA has treated US…

There are many different options for structuring the sale or purchase of a closely-held business, and determining the best option depends on several factors. The presentation linked below discusses some of the key points to consider when selling or acquiring a business. It also describes some of the most common…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2016: Short Term AFR…

As the baby-boomer generation ages, an increasing number of family businesses will be experiencing transitions in ownership and/or management. Not all of these transitions will be successful; popular studies indicate that only 30% of family businesses survive beyond the first generation. In some cases, a transition may be undermined by…

Real estate developers routinely use tax-exempt bond financing for infrastructure improvements for new communities. That may change soon. IRS perceives abuse in the process and has proposed regulations making such bonds taxable if the developer controls the issuing governmental body. Using enabling statutes under state law, a developer can initiate…