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Asset Acquisitions: Things That Make You Go HMMMM … Are You Really Entitled to That Beloved Occasional Sale Exemption?
This article analyzes the occasional sale exemption with particular emphasis on states that have narrow exemptions, cumbersome or perhaps counterintuitive requirements that must be satisfied in order for the exemption to ...
Call to the Texas Legislature: The Franchise Tax Needs Substantive Changes, Not Just Rate Reductions
This articles addresses one of several substantive issues that persist in the Texas Franchise Tax Code that requires the legislature’s attention. With the next legislative session set to begin in early 2017, the hope is ...
Taxation of Series LLCs in Texas: Bigger Isn’t Always Better in the Lone Star State
Texas’s Comptroller of Public Accounts announced a policy concerning the taxation of series LLCs in which all series of a series LLC should be aggregated and treated as a single taxable entity for Texas franchise tax ...
"Uncharitable” Policy for Charities: Use of Disregarded LLCs by I.R.C. § 501(c)(3) Organizations is a Trap for the Unwary in Certain States
This article explains how the imposition of the Texas Franchise Tax on Section 501(c)(3) Charities with subsidiary LLC structures in place arises. The article also discusses why there is no compelling reason for the ...