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Nathan provides legal counsel and tax advice for domestic and international transactions involving business assets and aircraft, including structuring, planning and drafting deals. He has been practicing in the area of multistate taxation since 1996. He counsels business clients in all areas of state and local taxes, including controversies, administrative proceedings, audits, appeals, litigation, and planning. Nathan has presented before numerous industry and professional organizations on various state and local taxation matters. A summary of Taft’s aircraft transaction experience is available here.

Prior to joining Taft, Nathan was the Indiana practice leader for Multistate Taxes at a national consulting firm. He also managed the tax function of a Fortune 500 insurance company headquartered in Indiana for more than four years.

Nathan earned his J.D. from the University of Michigan Law School and his Bachelor of Arts degree from Purdue University.

Generally, buyers of businesses want to buy assets so they can take a step up on a tax basis. Sellers prefer to sell stock, so their gain will be taxable at favorable capital gains rates. Some gain is usually taxable at higher ordinary income tax rates in an asset sale. Accordingly, S corporation owners who have been asked to sell assets typically request, and buyers typically agree to, an increase in the purchase price to account for the additional tax

Continue Reading Did you know that state tax PTE election may offset the additional tax on an S corporation asset sale vs. a stock sale?

Earlier this year, Indiana instituted new successor liability notice requirements for sellers and buyers involved in bulk transactions of businesses and business assets in Indiana. For deals closing on or after Feb. 14, 2024, and involving transfers of more than 50% of the tangible personal property of a business, transferees may be liable for the past due Indiana taxes of transferors, including penalties, and interest, up to the amount of the purchase price or value of the tangible personal property

Continue Reading Did you know Indiana Has a New Successor Liability Notice Requirement for Business Asset Transfers?

On February 22, 2023, Governor Holcomb signed Senate Bill 2 (SB 2), allowing elective pass-through entity taxation (PTET) for partnerships, S corporations, and LLCs taxed as S corporations or partnerships. The Indiana PTET and accompanying deductible expense election allow the pass-through of reduced federal taxable income to small Indiana business owners, thereby allowing qualifying owners to avoid the Federal $10,000 SALT deduction limit on their individual returns. Indiana law reflects a nationwide trend of state income tax responses to the
Continue Reading Did you know Indiana pass-through entity owners can make an election that allows a workaround for federal income tax limitations on state tax deductions?