How To Structure A Tax-Efficient IPO: Benefits Of The Up-C Structure

A partnership (or LLC) can go public in a highly tax-efficient manner by using an “Up-C” structure. An Up-C structure is composed of two entities: (1) a parent company, a C corporation (“PubCo”) which will be organized as a holding company, and (2) PubCo’s subsidiary, which is the partnership or LLC. The Up-C structure makes it possible for the partnership/LLC to undertake an IPO while maintaining its partnership status, principal assets and operating business. […]

By | May 30th, 2019 ||

Digital Tax Update: U.S. Legislators React To Unilateral Digital Tax Proposals

On April 10, 2019, the French National Assembly passed the Digital Services Tax (“DST”) proposal announced by its Finance Minister, Bruno Le Marie. The DST proposal must still be passed by France’s Senate but if ratified will be retroactively implemented to January 1, 2019. The impetus behind France’s proposed DST regime is to provide the French government with taxing rights over companies that do not have a physical presence in France but still derive […]

By | May 15th, 2019 ||

New York State Transfer Tax Changes

New York State has made changes to the State real estate transfer taxes that will apply to conveyances occurring on or after July 1, 2019. The changes generally increase the effective tax rates for certain real estate transfers and introduce a progressive rate structure so that higher-value transactions pay transfer taxes at increasingly higher rates. The changes to the State transfer taxes do not impact other transfer taxes (e.g., New York City real property […]

By | April 20th, 2019 ||