Jerald David August Attorney

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Map & DirectionsDirections222 Lakeview AveWest Palm Beach, FL 33401 Write a ReviewWrite Review

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Neighborhoods: Downtown West Palm Beach, Flagler-Waterfront District
AKA: August Jerald David
Categories: Patent, Trademark & Copyright Law Attorneys, Attorneys, Business Law Attorneys, Corporation & Partnership Law Attorneys, Criminal Law Attorneys, Tax Attorneys, Wills, Trusts & Estate Planning Attorneys

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Phone: (561) 835-9600

Address: 222 Lakeview Ave, West Palm Beach, FL 33401

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Jerald David August Attorney

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Business and Corporate Law

Corporate Law
In a recent article written by lawyers in the Aird & Berlis LLP law firm in Toronto, which was just published in Tax Notes International, U.S. international tax practitioners and business lawyers can obtain valuable insights on drafting issues and problems with Canadian controlled private corporation (CCPC) shareholder agreements. The idea is to preserve favorable tax attributes of a Canadian private corporation by ensuring that de jure and de facto control of the CCPC is maintained by Canadian persons throughout.
Mergers and Acquisitions
Jerry August is a nationally recognized tax lawyer who advises clients on income tax matters, including foreign taxation of U.S. businesses and U.S. taxation of foreign businesses and investors. He is frequently referred matters from outside law and accounting firms on choice of entity issues related to domestic or foreign business operations, structuring as well as assisting in the negotiation of mergers and acquisitions, both taxable and non-taxable, joint ventures, financings, workouts and recapitalizations. He has advised domestic and foreign public and private business entities, including private equity firms and hedge funds. Jerry also advises clients on tax and related matters as well as on tax disclosures required for SEC filings, IPOs and reserves for contingent tax liabilities. His legal representation extends to the domestic and international wealth planning areas, where he represents high net worth individuals, including non-residents, as well as non-citizen residents of the U.S., on both U.S. and foreign income and wealth tax matters.
Business Transactions
All countries, including underdeveloped countries, are well aware of the strain that has been placed on tax administrators throughout the world in grappling with the billions if not trillions of revenue loss associated with base erosion techniques and strategies utilized by many multinational business enterprises (MNEs) that are principally driven by tax avoidance and not primarily based on sound business practices. This base erosion is visibly greater when comparing the aggregate tax loss impact suffered by high tax jurisdictions from more modest tax jurisdictions. But as long as there is a moderate if not high level of taxation in a particular country, there are indeed many ongoing efforts to strip out earnings through interest, business transactions among related parties and nimble supply chain participants.
Limited Liability Companies
On October 5, 2016 the Internal Revenue Service and the Treasury issued Final and Temporary Regulations (T.D. 9788) pertaining to how liabilities are to be allocated and treated for purposes of applying the disguised sales rules under section 707 and when certain obligations will be as a recourse liability under section 752. Shortly thereafter, new proposed regulations (REG-122855-15) withdrew a portion of the recent rule-making to the extent not adopted in the final regulations and contain new proposed regulations on: (i) whether certain obligations to restore a deficit balance in a partner’s capital account are to be regarded (versus disregarded) for purposes of section 704; and (ii) when partnership liabilities are to be treated as recourse liabilities under section 752. These are important regulations obviously and, as reported in a prior blog post, will affect many if not most partnerships and their partners, including members of limited liability companies and limited liability limited partners. The regulations were to be effective on date of issuance with an important deferred date on the application of revisions to the disguised sales rules and liabilities until early next month. [1]
Intellectual Property

Trusts and Estates

Estate Planning
The Practical Tax Lawyer. For more than 30 years, he has served on the Board of Advisors of the New York University Federal Institute of Taxation August has been a guest lecturer at the University of Pennsylvania Law School and the University of Pittsburgh School of Law, and a visiting professor on corporate income taxation at the Graduate Tax Program of the University of Florida School of Law. Jerry is also a member of American College of Tax Counsel, the American College of Trust and Estate Counsel and the American Tax Policy Institute.
Trusts

Tax Law
The new tax law enacted in December swapped out a graduated corporate tax rate topping out at 35 percent with a flat 21 percent rate across the board. While this provision, combined with the elimination of the corporate alternative minimum tax (AMT), might seem to have simplified matters considerably, attorney Jerald David August, a tax partner at Kostelanetz & Fink...

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