As described in previous publications, M&A transactions are traditionally structured on a cash-free and debt-free basis. In the traditional sense, debt includes amounts owed to banks or other third-party lenders and is repaid over a set period of time at an interest rate dictated in the debt agreements.
It is critical for clients and practitioners to appreciate the Internal Revenue Service’s (“IRS”) historic positions and analysis regarding captive insurance companies, in order to fully understand the current captive insurance tax environment. The following discussion focuses on the relevant authorities contained in the Internal Revenue Code and Regulations, the current views of the IRS as set forth in administrative rulings and pronouncements and decisions dealing with what transactions qualified as insurance, and whether the activities of a related captive insurance company are those of a company primarily and predominately engaged in the insurance business.
Private, protected communication is the oxygen for the transfer of sensitive information in today’s environment. Unsecure communication makes us all vulnerable. It is essential that you understand possible weak points so that we all have the most robust, confidentially protected conduit for correspondence.
It’s hard to believe that over a year has gone by since the Tax Cuts and Jobs Act (TCJA) of 2017 was passed by Congress as one the most comprehensive changes to US taxation in over 30 years. The carried interest safe harbor, interest expense limitation and the corporate tax rate reduction are three of the most significant ways that the Tax Act has impacted private equity funds, their management companies and their portfolio companies.
Bennett Thrasher LLP is pleased to announce the election of six firm professionals to its partnership, effective July 1, 2019. The six represents Bennett Thrasher’s largest new partner class ever and includes individuals from six different practice areas: Financial Reporting and Assurance, International Personal Financial Services, Real Estate Hospitality Tax, Risk Advisory, State and Local Tax and Transaction Advisory Services
In 2018, Georgia passed House Bill 918 to modify and expand usage of Georgia tax credits, particularly for credits against Georgia payroll tax withholding. Georgia law permits taxpayers to elect to use certain income tax credits, such as the Jobs Tax Credit or Research & Development Tax Credit, against their Georgia payroll tax withholding obligations.
Leda Zhuang joined Bennett Thrasher in 2019 as a transfer pricing expert to support the existing practice led by Ben Miller. She has assisted numerous multinational firms with a global presence to evaluate and address their intercompany pricing matters for purposes of documentation, business restructuring, and tax planning.
Secondment (NOUN): the detachment of a person from his or her regular organization for temporary assignment elsewhere.
This past summer, the three of us had the opportunity to participate in a secondment with two firms in Australia – one in Sydney and one in Melbourne. The opportunity came to Bennett Thrasher in April 2018 from Scott Hazy, an audit partner within our firm who is well connected to our global affiliates through the DFK and LEA networks.
In an article published recently in Eli Financial Blog, James Pickett, a director in Bennett Thrasher’s Tax Controversy practice, discusses how taxpayers should handle the four basic IRS notice types, including collection and examination notices.
Although the firm welcomed 15 interns to the Bennett Thrasher family in January, we are busy preparing for our spring recruiting season. During the spring, the firm recruits for our summer leadership Break Through Conference, which will be held June 6-7 this year.
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