Tax Efficient S Corp Structures for Sellers

Legislative Decree No. 192 of 13 December 2024 and Decree-Law No. 84 of 17 June 2025 harmonise anti-avoidance rules governing tax loss carry-forwards across all M&A transactions. Furthermore, they introduce the free intra-group circulation of tax losses, exempting them from traditional statutory limitations. These measures create complex interactions that we try to break down in our post. An analysis of these measures is available on our website at the following link: https://lnkd.in/d8p-GGY3 #TaxLossCarryForwards #CorporateTax #TaxLaw #MandA #CorporateRestructuring

Most people skip the tax provisions in operating agreements. That’s a mistake. Hidden in that “gobbledygook” are clauses that can directly impact how profits, losses, and your tax liability are allocated. In our latest article, we break down the Qualified Income Offset and Minimum Gain Chargeback in plain English, so you understand what they actually do—and why they matter more than you think. Read the full article: https://lnkd.in/gZDTBGMw #AccordLawPLLC #TaxLaw #BusinessLaw #LLC #OperatingAgreements #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/rQHZ3R #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/pwguYH #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/iBjw1b #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/oK2lUE #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/4WK5uT #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/miqVzF #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/Kat3Fb #TaxLaw #SelfEmploymentTax #PartnershipTax

The Fifth Circuit's recent ruling in Sirius Solutions LLP is a significant development for limited partners and self-employment tax. The court held that state-law classification — not the services performed — determines eligibility for the limited partner exception under IRC Sec. 1402(a)(13). Full breakdown here: https://okt.to/DVeX1o #TaxLaw #SelfEmploymentTax #PartnershipTax