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Taking on debt with nonrecourse liability has several advantages. In general, when acquiring property subject to debt, the acquiring party stands to benefit more from nonrecourse debt rather than recourse. With that in mind, you may be asking yourself what exactly the difference is between...
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Reorganizations provide ways for corporate entities to restructure without triggering substantial tax consequences. It is important to remember with any reorganization that the strategy is rooted in tax deferral rather than tax elimination. The consideration used by the acquiring corporation, or subsidiary of an acquiring...
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FIRPTA, which stands for the Foreign Invest Real Property Tax Act, authorizes the United States government to tax foreign persons on the disposition of real property. The article below has been prepared by a Denver tax attorney to provide information related to FIRPTA. What is...
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As a general rule, the sale of assets or stock usually results in a taxable transaction to corporations. However, reorganizations create ways for entities to limit or reduce tax liabilities simply by restructuring the overall transaction. Tax free reorganizations should not be confused with eliminating...
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Selling a corporation can have significant tax consequences for both the buyer and seller. However, it is not impossible to satisfy both parties to the transaction with a §338(h)(10) election. Generally, sellers of corporate entities prefer to engage in a stock sale rather than an...
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