True Partners Insights

Pillar Icon

Partnerships/S-Corporations Insights

Michael O'Connor of TPC Mike O’Connor Moderates Panel Discussion at Transaction Advisors M&A Conference

Don’t miss this informative session and conference at the University of Chicago, September 25-26, 2019. Maximizing value through M&A tax structures This session will consider tax issues in due diligence, the tax benefits of various M&A structures, and look at key tax provisions in acquisition agreements. The participants will over perspective on recent tax developments that may impact transaction planning and explore the increasing use of tax liability insurance among other current […]

August 23, 2019

Taxation of Cloud Based Transactions – What do you see?

On August 14, 2019, the IRS released Proposed Treasury Regulation (“Prop. Treas. Reg.”) § 1.861-19 to provide rules for classifying a cloud based transaction (“CBT”) as either a lease of property or sale of services. This classification is critical to determine whether income and deductions are U.S.- or foreign-source, and it also has consequences for the calculation of the BEAT tax under Code section 59A (services are generally excluded from […]

August 19, 2019

Washington Tax Insight August 2019

Politics and Congressional Activity The Senate and the House approved legislation called the Bipartisan Budget Act of 2019 that would suspend the statutory debt limit until mid-2021 and lift the statutory caps on discretionary spending for the next two years (the “sequester”).  The President has said that he will sign the bill.  The budget deal does not include any tax measures, such as tax extenders, technical corrections, or retirement security […]

August 1, 2019