Insights and Updates

Comprehensive Global Tax Planning to Reduce the Global Effective Tax Rate

Posted on February 21, 2023 (April 17, 2024) by Christopher Klug

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. […]

Membership Interest for Services and Purchaser’s Tax Liability

Posted on February 15, 2023 (June 2, 2023) by Christopher Klug

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. […]

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

Posted on February 11, 2023 (June 2, 2023) by Christopher Klug

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. […]

The Importance of Not Overblocking for UBIT

Posted on February 6, 2023 (February 7, 2023) by Basswood Counsel

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. […]

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

Posted on January 4, 2023 (June 2, 2023) by Basswood Counsel

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. […]

Klug Counsel PLLC in 2022

Posted on December 27, 2022 (January 29, 2024) by Basswood Counsel

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. […]

Estate and Gift Tax Exemption Amount to Significantly Increase with Inflation

Posted on November 22, 2022 (December 27, 2022) by Basswood 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 […]

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

Posted on November 16, 2022 (January 29, 2024) by Basswood Counsel

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, […]

IRC §754 Election: Partner Signature No Longer Required for Partnership Basis Election

Posted on August 11, 2022 (June 2, 2023) by Basswood Counsel

Prepared by Gina Lee, Senior Associate at Klug Counsel Treasury and the Internal Revenue Service (“IRS”) have finalized regulations that eliminate the requirement that an Internal Revenue Code (“IRC”) 754 election statement to adjust the basis of partnership property be signed by one of the partners of the partnership to be valid. To understand the […]

Crypto Brokers and Exchanges Informational Reporting Likely Delayed

Posted on July 27, 2022 (June 2, 2023) by Basswood Counsel

The Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) are likely to delay a January date for crypto brokers and exchanges to begin tracking and reporting data such as customers’ capital gains and losses. The move will delay when the IRS receives the same kind of data from crypto transactions as it receives for […]

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