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Be Careful When Issuing Equity

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...

Final 2014 Form 1042 Released – Major Changes for FATCA Withholding

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...

For Mature Companies Only – Part Two

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...

President Obama Proposes Sweeping International Tax Reforms

President Obama Proposes Sweeping International Tax Reforms Jason Furman, President Obama’s Chief Economic Advisor, outlined proposals to be put forward by the Obama Administration, aimed at removing tax advantages for American multinational companies operating in low-tax jurisdictions. While Republican Senator Camp has proposed his own changes, including reducing the U.S. Corporate Income tax rate to...

For Mature Companies Only – Part One

For Mature Companies Only – Part One Commander #1:  We’ve analyzed their attack, sir, and there is a danger.  Should I have your ship standing by? Grand Moff Tarkin:  Evacuate?  In our moment of triumph?  I think you overestimate their chances. From the movie, Star Wars This is the first of a two-part blog –...

Preparing Your Early Stage Company for an Exit

Preparing Your Early Stage Company for an Exit Are you ready? Lyrics from the song of the same name – by Pacific Gas & Electric (circa 1970) So, I tend to blog about recurring items I see in our practice. In this case, over the last few weeks, we have been approached by a couple...

Business Models Are Not Business Plans

Business Models Are Not Business Plans Ace Ventura: [to Lt. Einhorn] Whew… now I feel better. ‘Course, that might not do any good; you see nobody’s missing a porpoise. It’s a dolphin that’s been taken. The common harbor porpoise has an abrupt snout, pointed teeth and a triangular thoracic fin. While the bottlenose dolphin, or...

IRS is Catching Up With Modern Technology: The Taxation of Bitcoin

IRS is Catching Up With Modern Technology: The Taxation of Bitcoin Bitcoin, the virtual currency that tech savvy consumers can use to purchase anything from the latest music on iTunes to a Lamborghini off a showroom floor, has been around since 2009 but just recently hit the radar of U.S. regulators. Recently, the IRS issued...