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New Jersey Business Lawyer | Business Formation | LLC  Limited Liability Company | IRS Tax | Business Purchase | LLC Lawyer
Some People Overpay the Government...But Certainly Not our clients!
Ronald J. Cappuccio, J.D., LL.M. (Tax)
Counsellor at Law
1800 Chapel Avenue West, Suite 128
Cherry Hill, New Jersey 08002 US
(856) 665-2121   Fax (856) 665-9005
Email: Ron@TaxEsq.Com


 
LLC Lawyer LLC Attorney

If there is any principle of the Constitution that more imperatively calls for attachment than any other, it is the principle of free thought—not free thought for those who agree with us, but freedom for the thought that we hate. . . . We should be eternally vigilant against attempts to check the expressions of opinions that we loathe. Supreme Court Justice Oliver Wendell Holmes

Helping Small and Emerging Businesses become more profitable!

Choosing the Best Legal Entity



THE TEN FEDERAL INCOME TAX ISSUES MOST LIKELY TO BE DECISIVE
IN TAX CHOICE OF ENTITY ANALYSIS

 

1)     Subchapter S eligibility and election requirements.  Do the
Subchapter S eligibility and election rules cause that subchapter to be
disadvantageous to an entity for federal income tax purposes as compared
with sole proprietorship taxation and Subchapter K?

2)     Contributions of appreciated property.  Which federal income tax
regimen provides the entity in question and its owners with the most
favorable federal income tax treatment with respect to contributions of
appreciated property to entities in connection with their formations?  

3)     Post-formation contributions of property.  Which federal income tax
regimen provides the entity in question and its owners with the most
favorable federal income tax treatment with respect to post-formation
contributions of appreciated property to entities?

4)     Special allocations and distributions.  Which federal income tax
regimen provides entities and their owners with the most favorable federal
income tax treatment with respect to special allocations and distributions
by entities to their owners?

5)     Distributions of property.  Which federal income tax regimen provides
entities and their owners with the most favorable federal income tax
treatment with respect to distributions of property by entities to their
owners? 

6)     Redemptions.  Which federal income tax regimen provides entities and
their owners with the most favorable federal income tax treatment with
respect to redemptions of ownership interests?   

7)     Sellers of ownership interests.  Which federal income tax regimen
provides the best federal income tax treatment to sellers of ownership
interests in entities?

8)     Purchasers of ownership interests.  Which federal income tax regimen
provides the best federal income tax treatment to buyers of ownership
interests in entities? 

9)     Inclusion of entity debt in owner basis.  Which federal income tax
regimen provides the best federal income tax treatment to owners with
respect to the inclusion of entity debt in owners' bases in their ownership
interests? 

10) Grants of restricted ownership interests and options to purchase
ownership interests.  Which federal income tax regimen provides the best
federal income tax treatment to entities and their owners with respect to
the granting of restricted ownership interests and of options to purchase
ownership interests?


















Ronald J. Cappuccio, J.D., LL.M.(Tax)
, a LLC Lawyer and Business and Tax Attorney.  We can help you start a Limited Liability Company ( LLC ) which can be the best form of business organization, as well as establish Corporations, S Corporations, Partnerships, Limited Partnerships and Non-Profit organizations. We also can represent you in Buying and Selling a business. helping emphasizing Personal and Business IRS Tax Negotiation,
Offers In Compromise, and Installment Agreements. Zealous representation in Tax Audits, Delinquent Tax, and Tax Collections Issues. Experience fighting Employee and Independent Contractor issues, Payroll Taxes, Tax Liens,and Tax and Labor Audits. Successfully handle Wage Levy Release, Bank Levies and Seizures.  NJ Tax Court, US Tax and US Court of Federal Claims representation. 
                
We also can represent you in Buying and Selling a business.