Strategic tax issues for capital markets

International tax adds extra complexity for PE funds considering holding companies

1/7/2020 | Eytan Burstein

During acquisition structuring, PE funds must decide not only whether to form a holding company, but also where to form one. Consider these five international tax factors.

Avoid missteps during purchase price allocation

12/12/2019

In a taxable asset transaction, once the diligence process is over and purchase price adjustments have been negotiated, the total purchase price must still be allocated to all of the tangible and intangible assets acquired, some of which may not have been previously recorded on the target’s books or have tax basis.

GILTI raises issues with downward attribution and compliance

11/20/2019

The global intangible low-taxed income (GILTI) regime applies to 10% or more U.S. shareholders in controlled foreign corporations (CFCs) – entities in which these U.S. shareholders own more than 50% of the stock by vote or value. The law generally requires them to include their share of the net income of that CFC as taxable income.

State taxes – Are you covered? Considerations for private equity fund managers

10/24/2019

Over the past two years, due to tax reform and judicial action, state tax rules have become more complicated and burdensome than ever.

Mergers and acquisitions

Financial sponsors, strategic investors and business executives harness the power of mergers and acquisitions to accelerate growth and maximize value. Market conditions, economic factors and innovative deal strategies can influence the outcome of a well-thought M&A plan. Here, CohnReznick's deal team, industry experts and advisors, offer insight and observations to help dealmakers achieve their vision.

QSBS - One of today’s most powerful yet often overlooked tax planning tools for VCS & company founders

4/10/2019

Section 1202 encourages investment in new ventures and small businesses by providing significant tax relief. This very attractive tax incentive offers up to 100% capital gain exclusion on certain dispositions of Qualified Small Business Stock (QSBS) acquired after September 27, 2010.

5 key factors to consider before making a cannabis acquisition

4/15/2019 | Beau Whitney & Andrew Lines

With talk of a looming recession, many analysts predict that during a downturn there will be a short list of growth industries that can deliver a healthy return on investment. Cannabis is near the top of that list. In fact, spending on legal cannabis in the U.S. is expected to increase from the current $12.9 billion to $20.4 billion in 2022, according to New Frontier Data.

The Wayfair Decision: Economic nexus and the impact on marketplace collection for sales tax

Join us for an informational discussion on the impact of the marketplace facilitators obligations, the risks involved and policies and compliance procedures you should already have in place.

Tax reform

With the passage of the Tax Cuts and Jobs Act (“Act”), there is much concern, as well as confusion, as to the impact the new legislation has on both businesses and individuals alike.

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