Structuring the Closely Held Enterprise for Dynamic Growth (With a Focus on the Restaurant/ Bar Industry)

摘要

Complicated closely held capital arrangements can lead to improved economies of scale and lower equity costs of capital, approaching publicly held capital economics. This article shows how incremental factors can develop closely held businesses for dynamic growth. These factors involve (1) Whiteco Industries, Inc. modular structure tangible personal property factors in relation to the transitory special-allocation conclusive presumption, (2) C corporation environment FLSA and Section 45B credit strategies, and (3) Affordable Care Act, ERISA, and multiple tax benefit controlled group considerations.