M&A activity during Q1 2024 has experienced the strongest start in two years, with over $549B in global deal volumes, representing a 28% increase from Q1 of 2023. However, gone are the days of easy financing and 0% interest rates – the federal funds rate is currently between 5.25% - 5.50%, forcing taxpayers to rethink their deal structures and consider certain tax cost optimizing strategies, which are discussed in this article.
Contracts, Signing Bonuses, and the Substantial Presence Test
Amber Gray-Fenner, EA NTPI Fellow USTCP
In tighter job markets, recruits are often offered signing bonuses (and sometimes moving expenses) to join a firm. Sometimes construction workers temporarily relocate to jobs in other states while they are employed by the company that hired them in their home state. This article reviews some of the foundational tax concepts to consider when evaluating sourcing of income for state tax purposes.
