Norris McLaughlin & Marcus, P.A.

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Business and Tax Planning

Jan 19, 2018

IRS Issues Guidance for New Repatriation Tax

Many U.S. owners of foreign companies are surprised to hear that the new repatriation tax not only applies to “repatriated” foreign earnings, but also to foreign earnings that are not repatriated into the U.S.   They are even more surprised to learn that the deemed repatriation tax may be due as early as the 2018 tax season. While an election is available to pay the net tax liability over eight annual installments, this new tax comes as a surprising frustration to many business owners of foreign companies.» Read More

Sep 14, 2017

2017 Lawsuit Climate Survey: Ranking the States

The U.S. Chamber Institute for Legal Reform just released its 2017 Lawsuit Climate Survey: Ranking the States.  Sometimes this information can be useful to help a business decide where to locate, where to do business (or not), and where to litigate.  This information can also be useful at times to make an argument in Court that a jurisdiction has become a favored venue (and why) for Plaintiffs from out of state, and might help support a forum non-conveniens motion. » Read More

Aug 28, 2017

How An “F” Reorganization Can Help Your Business

An “F” reorganization is a type of tax-free reorganization under Internal Revenue Code Section 368(a)(1)(F), which includes a mere change in identity or form of one corporation.  F reorganizations are typically used to effectuate a tax-free shift of a single operating company. They are frequently used as part of a pre-sale strategy or for changing certain undesired attributes of an operating company. » Read More

Jun 29, 2017

Guidance for Companies Picking a State for Operations in the U.S.

New District Court Opinion Discussing the Scope of Specific Jurisdiction After Bristol-Myers Squibb Co. v. Superior Court of San Francisco County,582 U.S. ____ (2017) – Wow, that was quick!» Read More

Jun 20, 2017

New U.S. Supreme Court Opinion Concerning Specific Jurisdiction in U.S. State Courts

The United States Supreme Court issued its long-awaited opinion in Bristol-Myers Squibb Co. v. Superior Court of San Francisco County, 582 U.S. ____ (2017).   Fortunately, the Supreme Court resisted the opportunity to revisit the limited scope of general jurisdiction discussed in Daimler AG v. Bauman, 571 U.S. _____ (2014), or to expand the existing grounds for specific jurisdiction.   It maintained its prior view of specific jurisdiction and required “a connection between the forum and the specific claims at issue.”  See the opinion here for more detail.» Read More

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