Taxation of Founder Stock & The 83(b) Election

By | 2017-08-17T06:20:54+00:00 August 16th, 2017|Taxes|

In Previous Article, we saw how Section 83 of the Tax Code operated under different circumstances, and how an entrepreneur or founder could utilize the election provisions of Section 83(b) to lock-in the taxable value of equity. In this article [...]

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Key Legal Issues Facing Start-Ups: Section 83(b) of the Tax Code

By | 2017-08-17T06:32:48+00:00 August 9th, 2017|Acquisitions, Financial|

In the Previous Article, we explored how Section 83(a) of the Tax Code taxes the receipt of “property” (i.e., equity) by a “service provider” (i.e., the entrepreneur) “in connection with the performance of services” (i.e., working on the business).  This [...]

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Minimizing (or Eliminating) Taxation Under Section 83(a)

By | 2017-08-17T06:37:58+00:00 August 9th, 2017|Financial, Governments, International, Taxes|

As discussed in Previous Articles, we saw how Section 83(a) of the Tax Code imposes ordinary income tax on “property” received by a “service provider” “in connection with the performance of services.”  We also saw that Section 83(a) postpones taxation [...]

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Key Legal Issues Facing Start-ups: Choice of Entity

By | 2017-08-17T06:31:09+00:00 August 9th, 2017|Financial, Taxes|

A key issue facing start-ups is choosing an entity form. The primary options are: C Corporations, S Corporations, Partnerships and Limited Liability Companies (LLCs). Each has advantages and disadvantages, and each presents unique issues. This article will present only the [...]

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Key Legal Issues Facing Start-Ups: Section 83(a) of the Tax Code

By | 2017-08-18T15:17:00+00:00 August 9th, 2017|Taxes|

Section 83(a) of the Tax Code says that a “service provider” that receives “property” “in connection with the performance of services” must pay tax on the difference between the value and the amount paid for the property. This seemingly innocuous [...]

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