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IRS Form 5471

Federally Tax-Exempt And/Or Nonprofit International Tax Series: Form 5471

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Table of Contents1 Summary:1.1 When is a tax-exempt and/or nonprofit entity or organization required to file form 5471?1.2 Why should a TE and/or NP organization care if had or has a form 5471 filing obligation?1.2.1 What can be done to prevent the form 5471 penalty?1.2.2 Where does form 5471 get filed?1.2.3 How can a TE […]

Benefits of Hiring A Tax Attorney in Denver

Benefits of Hiring A Tax Attorney in Denver

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Table of Contents1 Hiring a Tax Attorney in Denver Before Tax Season2 What Is A Tax Attorney?3 Understanding Tax Policies3.1 Filing Tax Returns3.2 Protect Your Finances and Property3.3 Tax Disputes3.4 Maintain Your Credit3.5 Tax Fraud or Evasion3.6 Protection From Litigation3.7 Intermediary Working For You4 Let JM Tax Law Provide You With The Most Benefits Of […]

Do You Need a Business Attorney in Denver

Do You Need a Great Business Attorney in Denver?

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Table of Contents1 The McGuire Law Firm Business Attorney Denver1.1 Why You Need a Business Attorney in Denver1.2 Determine Why You Need a Business Attorney in Denver1.2.1 Choose the Right Entity Type1.2.2 Drafting Legal Documents1.2.3 Navigating Securities Laws1.3 Finding a Business Attorney In Denver1.4 Helpful Questions To Ask a Business Attorney1.4.1 Business Formations1.4.2 Mergers, Acquisitions, […]

IRS Streamlined Offshore Voluntary Disclosure Program (OVDP)

9 Q&A’s About The IRS Streamlined Offshore Voluntary Disclosure Program

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Table of Contents1 The IRS Streamlined Procedures Q&A’s2 What is the Procedure for the IRS Streamlined Offshore Voluntary Disclosure Program?2.1 How is the 5% Streamlined OVDP Penalty Calculated?3 What is “Non-Willful” for Purposes of the IRS Streamlined OVDP?4 What is Form 14654?5 Where do I File FBARS When Going Through the Streamlined OVDP Process?5.1 How […]

What U.S. Citizens Should Know About Form 5471 (2)

What U.S. Taxpayers Should Know About Form 5471

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Table of Contents1 What Is Form 5471? 1.1 What Is A Foreign Corporation?1.2 How Much Of The Foreign Corporation Do You Own?1.2.1 Direct Ownership1.2.2 Indirect Ownership1.2.3 Constructive Ownership1.2.4 A Quick Example Of How The 318 Rules Can Play Out2 Categories of US Persons Who File Form 54712.1 Category 1 Filers (Sec. 965)2.2 Category 2 Filers (Sec. […]

Forward Triangular Merger

Forward Triangular Merger

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Table of Contents1 Common Use for a Forward Triangular Merger2 Where Forward Triangular Mergers are Prevalent3 Three Critical Things to Remember in a Forward Triangular Reorganization4 Key Takeaways As discussed previously in other articles, reorganizations can provide a way to restructure business entities or acquire others without experiencing high tax costs. In other words, reorganizations offer ways […]

Non-Recourse Liability and Debt

Non-Recourse Liability and Debt

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Table of Contents1 Advantages of Taking on Debt with Non-Recourse Liability2 Concerns when Obtaining Property Subject to Non-Recourse Debt3 Key Takeaways4 Special Considerations Advantages of Taking on Debt with Non-Recourse Liability Non-recourse debt means that if the debtor defaults, the creditor cannot pursue the debtor personally. Instead, the creditor must seek recovery from the collateral […]

Important Information About B Reorganizations

Important Information About B Reorganizations

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Table of Contents1 What are Reorganizations?2 What Are B Reorganizations?3 What Are The Control Requirements For B Reorganizations?4 What Type of Consideration May Be Used In B Reorganizations?5 Can B Reorganizations Occur Over a Series of Transactions?6 Will There Still Be Minority Shareholders?7 Key Takeaways8 Conclusion What are Reorganizations? A reorganization allows a company to […]