Entries by Manager

International Tax Lawyers | Passive Foreign Investment Company

Congress enacted the Passive Foreign Investment Company provisions (PFIC) as part of the Tax Reform Act of 1986 in order to deter U.S. investors from deferring or avoiding payment of U.S. taxes by investing in offshore entities. The PFIC rules are structured to provide a disincentive for U.S. investors to defer investment income taxes by […]

Capital Gains and Losses: Tax Implications for Individuals and C-Corporations

Capital gains and losses defined Capital gains and losses result from the taxable realized sale or exchange of capital assets. In general, capital assets include investments (such as stocks and real estate) and fixed assets, as opposed to personal-use property. Capital gains result when the sale or exchange price is greater than the adjusted basis […]

Preparing for Business Contract Litigation in Minnesota: Recordkeeping Techniques

Since most of the business-to-business relationships are organized on the basis of written business contracts, it is inevitable that contract disputes would arise between businesses. Frequently, these disputes are serious enough to lead to business contract litigation between the relevant parties Therefore, it is important for any business to prepare for such a possibility ahead […]