Critical insights into Mergers & Acquisitions, covering tax due diligence, business valuation, and the tax implications of various deal structures.
Does the new SBA quality of earnings rule apply to my deal? If you are using an SBA 7(a) loan to buy a business or expand into one for $3 million or more, yes. Starting October 1, 2026, lenders must obtain an independent SBA quality of earnings report before the loan can close on that…
What changes for a dental practice acquisition in 2026? If you are buying with an SBA 7(a) loan of $3 million or more, an independent quality of earnings report becomes mandatory on October 1, 2026 — and the lender has to engage the provider before your loan number is issued. Most dentists buying a practice…
How do partnership merger tax rules work under Sec. 708(b)(2)(A)? A resulting partnership is a continuation of any merging partnership whose partners own more than 50% of the capital and profits of the resulting partnership; other merging partnerships terminate. Consideration mixing cash and interests triggers disguised-sale analysis, and the merger cash-out rule at Regs. Sec….
What does Rev. Proc. 2026-21 change about IRS letter rulings on corporate transactions? Rev. Proc. 2026-21 establishes a new letter ruling program under the Associate Chief Counsel (Corporate) — modifying Rev. Proc. 2026-1 and 2026-3 to expand the scope of significant-issue and transactional rulings available for §§ 332, 351, 355, 368, and 1036 reorganizations, while…
Is an APA the right tool for your multinational’s transfer pricing strategy? An advance pricing agreement 2026 locks in an IRS-approved transfer pricing method for up to five prospective years, eliminating audit risk and double taxation for multinationals operating between the US and foreign jurisdictions. For multinational companies with intercompany transactions crossing US borders, transfer…
Confused by startup funding? 🤯 Discover the SAFE (Simple Agreement for Future Equity), the simple document that’s changing the game for founders and investors. We break down how it works, from valuation caps to discounts, and why it’s all about one thing: speed. You have it. That billion-dollar idea that just woke you…
Signing a US Startup Investment Contract? Don’t sign until you read this. We expose the 5 hidden clauses that can cost founders millions and how to protect yourself. Okay, so if you’re a founder, that moment you finally get a term sheet from a VC is one of the best feelings in the world….
Navigating the July 2025 M&A Market? From Seoul to New York, the landscape is buzzing with strategic shifts. This post breaks down the key deals and trends you need to know to guide your investment strategy. Have you been watching the M&A market lately? It feels like every day brings news of another major…
