The issuance of a partnership profits interest is a tax-efficient tool for a partnership (including an LLC or other entity treated as a partnership for tax purposes) to incentivize its employees or other service providers. If structured properly, the grant of a profits interest should not constitute a taxable event for the recipient. In addition
Section 338(h)(10) of the Internal Revenue Code can provide significant tax benefits to a buyer of 80% or more of a target corporation. A 338(h)(10) election allows a buyer of stock of an S corporation or a corporation within a consolidated group to treat the transaction as an acquisition of 100% of the assets of
Introduction
When reviewing U.S. stock option plans for our foreign clients, we are constantly asked to explain the difference in tax consequences between incentive stock option (ISO) plans and nonqualified stock option (NSO) plans. This is a frequently asked question as many U.S. companies offer their employees options to buy company stock at a specified