Settlement Costs and Legal Fees Stemming from Corporate Reorganization Are Non-Deductible If a capital transaction produces litigation, the potentially resulting settlement costs and associated legal fees are capital acquisition costs. As such, these amounts cannot be deducted. This was the holding in the recent court case Ash Grove Cement Company vs. U.S., 113 AFTR 2d…
Be Careful When Issuing Equity Vinny Gambini: You were serious about dat? Quote from My Cousin Vinny What prompts this blog comes from a conversation with one of my partners recently. He had been served with his first subpoena on a client where we had only offered some tax advice. Fortunately for us, it had…
Credit Suisse Agrees to Pay $2.6 Billion in Guilty Plea of U.S. Tax Evasion The U.S. Department of Justice and the IRS have announced that Credit Suisse AG pleaded guilty on May 19, 2014, to conspiracy to aid and assist U.S. taxpayers in filing false income tax returns with the IRS. With this guilty plea,…
The CFO and Working Capital Management: How to Manage Your Debt Strategy Managing liquidity and operational needs is a delicate balance for all CFOs. Companies must ensure that they borrow based upon necessity, while at the same time limiting the cost of overburdensome borrowing. Ultimately, your credit quality and loan structure will impact the risk…
Do Hedge Funds Need To Be Consolidated? A proposed accounting standards update, Financial Services-Investment Companies (Topic 946) has been issued by the Financial Accounting Standards Board which leads to a number of questions, one of which is to consider whether hedge funds need to be consolidated. Let’s take a brief look at this proposed accounting…
Retailers Beware and Be Smart: Take Measures to Help Protect Against Cybercrime and Minimize Your Exposure Many retailers around the country have been feeling a little uneasy after the FBI released a report entitled, “Recent Cyber Intrusion Events Directed Toward Retail Firms,” warning everyone that cyber-attacks similar to the one suffered by retail giant Target…
Final 2014 Form 1042 Released – Major Changes for FATCA Withholding The IRS has released the final version of the 2014 Form 1042, the Annual Withholding Tax Return for U.S. Source Income of Foreign Persons. The newly released form reflects changes for the new FATCA withholding rules. The circumstances for which Form 1042 must be…
Historic Rehabilitation Tax Credit Do you own, lease or are you considering purchasing a building in a historic district? The property may already be listed on the National Park Services (NPS) National Register of Historic Places, but if not, you can apply to the NPS for inclusion on the list if your property meets certain…
For Mature Companies Only – Part Two Ace Ventura: “I have exorcised the demons . . . this house is clear.” From Ace Ventura – Pet Detective In my prior blog, I outlined a few ideas around why mature companies should remain vigilant regarding the potential for Disruptive Technologies (which are not always technologies) in…
Cooperative Business Organizations In the economic times that we find ourselves operating in, most businesses are dealing with decreases in revenue, increases in operating costs and increasing financial pressures put on them by their financial institutions. One overlooked alternative to assist in controlling costs and purchasing function is the cooperative business organization. These organizations are…