business valuationtaxationpersonal goodwillGoodwill is a nebulous concept that is often not handled properly by taxpayers or the IRS. Two recent Tax Court cases highlight the IRS's flawed approach and methodology to goodwill in two particular situations: the effect of goodwill in a corporate ...
Presents information on building a business in Australia which could end up giving an investor a substantial tax break on goodwill assets. How 50 percent of any gain from the sale of goodwill is potentially tax free; Comments from Leo Hollestelle of the Hollestelles tax consultancy; Other tax...
the selling shareholders' perspective, if the first component of the transaction involves a sale of the target C corporation's assets, the portion of the purchase price attributable to the personal goodwill component of the transaction does not bear the burden of a corporate level of taxation. ...
GoodwillTax Court DecisionsTax PlanningDouble TaxationLiquidationTwo recent Tax Court decisions, Martin Ice Cream Company v. Comm'r [110 TC 189 (1998)] and Normalk v. Comm'r (T.C. Memo...
3. Subsequent Changes Leave One-Sided Punitive Regime ... 4. Discontinuities in Trademark Litigation ... 5. Summary ... C. Business Sale Override of §§ 1221(a)(3) and 1235V. Conclusion 展开 关键词: taxation goodwill intellectual property 年份: 2018 ...
b. Example 2B: Sale of Bud's Bar & Grill ... 2. Fixed-Consideration IncentivesIV. Responses to Goodwill Hunting Gone Bad ... A. Replace Goodwill Sourcing Exception with Foreign Taxation ... 1. Underlying Goals of § 865(d)(2) and (d)(3) ... 2. Goodwill as a Poor Proxy for...