The passive activity loss rules of Section 469 of the Internal Revenue Code limit the losses that an individual, trust, estate, closely held C corporation, or a personal service corporation can recognize from trade or business activities in which the taxpayer does not “materially participate.”

The following fact-based analysis, which contains nearly 200 identified references, is a must-read for every
concerned U.S. citizen. Alvarez & Marsal’s Healthcare Industry Group analyzed the $2.6 trillion healthcare
sector to better understand the potential impact of the PPACA. This analysis takes a convergent view across
the healthcare industry spectrum, incorporating multiple vantage points; from clinical medicine to hospital
system C-suites and employers; from the finance community to public policy leaders.

Frank Underwood likely would appreciate that as tax advisors, we are often called upon to fight chaos with chaos. Chaos, of course, describing the present state of our tax system. One particularly chaotic area is determining what constitutes “reasonable compensation” for U.S. federal income tax purposes, particularly with respect to closely-held corporations.

The last couple of years have seen positive changes mainly in the form of additional tax allowances to encourage investment in both offshore UK Continental Shelf (UKCS) exploration and onshore exploration for unconventional hydrocarbons (e.g., shale gas)

Alvarez & Marsal Asset Management Services, LLC is an independent affiliate of Alvarez & Marsal Holdings, a global professional services firm with a 30-year track record of maximizing asset value in connection with scores of business transformations. A&M's announcement follows decades of successful asset management assignments, including A&M’s oversight of the historic wind-down of Lehman Brothers Holdings Inc. – a precedent-setting case in which A&M successfully managed and maximized the value of commercial real estate, residential mortgages, private equity and principal investments, corporate loans, derivatives and other long-term distressed and illiquid assets.

In light of the impending global war for corporate tax revenue, this article outlines an audit strategy based on the Eight Rules of Air Combat written for fighter pilots in World War I and applies four of those rules to help companies prepare for tax audits in order to favorably resolve tax controversies.

For many companies, it happens every three to four years like clockwork — you receive a questionnaire or letter with those infamous words "you have been selected for a sales and use tax audit.

It’s a tale as old as time itself: Buyer meets seller. Buyer falls in love with seller’s business. Buyer proposes to seller.

Restaurants continue to be attractive targets for investors and strategic acquirers as many eateries offer appealing ways to deploy capital and diversify. In fact, there were 132 announced restaurant transactions in 2013; and activity remained strong throughout the first quarter of 2014 with 31 announced restaurant transactions, according to S&P Capital IQ. However, savvy investors must understand the unique accounting considerations associated with restaurants, and carefully include operational improvement and other initiatives into any investment thesis.

Software-as-a-Service (SaaS)1 is no longer an emerging technology segment. It’s big and getting bigger – and here to stay. The technology research and advisory firm IDC predicts that spending on private cloud services will grow from $9 billion in 2013 to $24 billion in 20162 – and public IT cloud services spending will grow from $47 billion in 2013 to $107 billion in 2017.3

This edition of Tax Advisor Weekly is a follow-up to an article previously posted, “Entity Simplification: Not So Simple (But Likely Beneficial).”

As we noted, research that is reimbursed by your customers can qualify if, pursuant to the contract, you are economically at risk and you retain substantial rights in the research conducted.

Merger and acquisition cycles are fueled by many forces, not least among them being the strategies promoted by activist investors and investment banking advisors. Once in favor, conglomerates dotted the industrial landscape. However, within the past several years, the scale, adjacent market synergies and potential integration benefits of an aggregation strategy have been counter-balanced by arguments for better management focus and clearer market / equity analyst communications.