Insights

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.

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.

Bennett Thrasher is pleased to present the results from the 2019 National Manufacturing Outlook and Insights Survey. Participants from across the U.S. provided insight in the survey, in conjunction with the Leading Edge Alliance (LEA) and other LEA firms.

The White House Office of Management and Budget (OMB) announced Monday, January 7, 2019, that the IRS will pay tax refunds during the shutdown.  This is a change from the previous policy announcement.

In last summer’s landmark decision of South Dakota v. Wayfair, Inc. (“Wayfair”), the US Supreme Court upheld South Dakota’s economic nexus law, which requires companies to collect sales tax when their sales or number of transactions with that state exceed certain thresholds.

As you may have heard, the Federal Government partially shut down on December 22, 2018 due to a budget impasse between the current administration and Congress.  This shutdown includes the Internal Revenue Service (IRS).

Bennett Thrasher is pleased to announce the release of our 2018-2019 Tax Guide. This guide provides an overview of the most consequential changes under the Tax Cuts and Jobs Act and other key tax provisions that taxpayers need to be aware of.