Kendall J. Keshtkar

May 6, 2024 | jdsupra.com | Kendall J. Keshtkar |Richard C. LaFalce |Sarah-Jane Morin

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892 of the Internal Revenue Code of 1986, as amended (the Code), providing guidance related to “domestically controlled” qualified investment entities and exemptions for foreign government investors, respectively.

May 3, 2024 | morganlewis.com | Richard C. LaFalce |Sarah-Jane Morin |Daniel Nelson |Kendall J. Keshtkar

On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892 of the Internal Revenue Code of 1986, as amended (the Code), providing guidance related to “domestically controlled” qualified investment entities and exemptions for foreign government investors, respectively.

Jun 14, 2023 | jdsupra.com | Barton Bassett |Daniel Carmody |Kendall J. Keshtkar

Creating a financial technology (fintech) firm comes with a host of tax considerations and implications. Decisions about the business’s structure, along with the location of both the business itself as well as its employees, can affect the entity’s tax obligations. FORMATIONCharacteristics of a fintech business and specific concerns of the business owner(s) will ultimately drive its structure.

May 26, 2023 | jdsupra.com | Daniel Carmody |Kendall J. Keshtkar |Scott Lee

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.

May 25, 2023 | lexology.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson |Scott Lee |Kendall J. Keshtkar

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.