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Tax Planning for Foreign Investors

Tax Planning for Foreign Investors

With the global economy we live in, it is important for Fund Managers to have an appropriately structured fund if they plan to have foreign investors.  Too often, the fund structure is not tax efficient for the foreign investor.  If the fund is not structured to accommodate foreign investment, why should a foreign investor consider investing in the fund? […]

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Comprehensive Planning to Provide the Most Tax-Efficient Structure

Comprehensive Planning to Provide the Most Tax-Efficient Structure

CFOs and General Counsel of multinational corporations (non-U.S. parent) with operations in the United States face complex tax implications that must be planned for on a global basis and not make decisions solely based on the U.S. tax implications. Too often, the U.S. advisor will ignore the tax implications from other relevant jurisdictions to the financial detriment of the multinational corporation. Through our associated networks and our team, we are able to plan for the tax strategy of the multinational corporation to provide a global framework by continually evaluating the multinational group’s operational and tax position and provide solutions that address key considerations. […]

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Comprehensive Global Tax Planning to Reduce the Global Effective Tax Rate

Comprehensive Global Tax Planning to Reduce the Global Effective Tax Rate

CFOs and General Counsel at U.S. multinational corporations are confronted with complex international tax that requires comprehensive global tax planning to reduce the global effective tax rate. Without a comprehensive strategy that considers not only the tax implications of the country where the transaction occurs, but also analyzing the tax implications back to the U.S., planning strategies may bring little to no actual benefit to the U.S. multinational corporation. Our team proactively plans for the tax strategy of U.S. multinational corporations to provide a global framework by continually evaluating the company’s operational and tax positions and respond with a tax analysis that addresses the key considerations. […]

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Membership Interest for Services and Purchaser’s Tax Liability

Membership Interest for Services and Purchaser’s Tax Liability

The after-tax proceeds of the sale of a business is of the utmost importance to sellers. Too often sellers agree to holdbacks or a reduction in purchase price for alleged tax issues raised by the purchaser during due diligence where the purchaser bears no actual risk. […]

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Comprehensive Approach to Tax Planning for U.S. Multinational Corporations

As multinational corporations continue to expand their operations globally, they must navigate a complex web of tax regulations and laws. It is essential that they take a comprehensive approach to tax planning and not make decisions solely based on the U.S. tax implications. […]

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The Importance of Not Overblocking for UBIT

The Importance of Not Over Blocking for UBIT

Taxes play an important role in the structure of a fund. There are various categories of investors that have different tax implications which will impact the structure of a tax efficient fund. One such group of investors are tax-exempt investors and the planning around Unrelated Business Income Tax (“UBIT”). A common planning strategy for UBIT is placing a blocker corporation in the structure. If the blocker corporation blocks more than the UBIT, the tax-exempt investors will have their investment earnings reduced unnecessarily. […]

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IRS Delays Implementation of $600 Threshold for Third-Party Payment platforms’ Forms 1099-K

IRS Delays Implementation of $600 Threshold for Third-Party Payment platforms

For calendar years beginning after December 31, 2022, the third-party payment organizations are required to report payments in settlement of third-party network transactions with any participating payee that exceed a minimum threshold of $600 in aggregate payments, regardless of the number of such transactions. […]

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Klug Counsel PLLC in 2022

We hope you and your family are healthy, safe, and enjoying the holiday season to end 2022. We would like to take this opportunity to update you on exciting developments at Klug Counsel PLLC. We are excited about new members and practice areas that have been added to the firm and the creation of a related entity that will allow us to better serve our clients with accounting and finance support. […]

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Estate and Gift Tax Exemption Amount to Significantly Increase with Inflation

Estate and Gift Tax Exemption Amount to Significantly Increase with Inflation | Klug Counsel

Prepared by Gina Lee, Senior Associate at Klug Counsel Every year, the estate and gift tax “basic exclusion amount” (commonly known as the “estate and gift tax exemption amount”) is adjusted for inflation. The Tax Cuts and Jobs Act passed in 2017 doubled the estate and gift tax exemption amount from $5 million to $10 […]

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IRS will Prioritize Enforcement Under $80B Funding: Large Business and International Division

IRS 80B funding

Prepared by Arturo Meza, Foreign Associate at Klug Counsel On August 16, 2022, President Biden signed the Inflation Reduction Act into law. As part of the significant changes made by this legislation, the IRS will receive a budget increase of nearly $80 billion over the next ten years to improve four areas: enforcement, operations support, […]

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