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Limited Liability Company (LLC) C-Corporation Internal Revenue Service

Keating Muething & Klekamp PLL

Leto v. United States: How a Taxpayer’s Section 1202 Exclusion Could Have Been Saved

In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The ManyTraps That Exist For The Unwary: Part I – The...

Foster Garvey PC on

In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary. This year, in a multi-part article, I intend to take our blog...more

Allen Barron, Inc.

It’s Time to Start Making Estimated Tax Payments Again California

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The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more

Obermayer Rebmann Maxwell & Hippel LLP

S Corporation Tax Pitfalls - The Dreaded Inadvertent S Election Termination

Business owners are often attracted to the S Corporation as a hybrid between the entity-level tax planning opportunities afforded by C Corporations and the passthrough nature of a partnership, all while affording a business...more

Foley & Lardner LLP

Common Diligence Issues for Startup and Emerging Technology Companies

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As an emerging or startup technology company seeking funding, your focus is likely on your product - it is the core of your business. That being said, how you protect your technology and set up the company that owns it can be...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

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I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Foley & Lardner LLP

Qualified Small Business Stock: Some Interesting Questions

Foley & Lardner LLP on

Section 1202 is a once-obscure tax saving provision that has come into prominence in the last few years. Originally passed in 1993 as a 50% capital gain exclusion, it has been amended several times since. In its current...more

Faegre Drinker Biddle & Reath LLP

Selling an LLC? Don’t Forget About 280G!

Internal Revenue Code Section 280G (280G) (commonly referred to as the golden parachute provision) is intended to discourage the payment of excessive compensation to certain shareholders, officers and highly compensated...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Arkansas's Answer to the SALT Cap for Business Owners: The Arkansas Pass-Through Entity Tax Act

The Tax Cuts and Jobs Act of 2017 (The “TCJA”) imposes a $10,000 cap on the amount an individual may deduct for federal tax purposes for the payment of state and local income, property and sales taxes (referred to as “SALT”)....more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

Rivkin Radler LLP on

What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Farrell Fritz, P.C.

New York’s Post-Election Tax Environment For Business Owners

Farrell Fritz, P.C. on

Something Is Rotten- There’s a gray pall hanging over New York that has clouded the judgement of many politicians, and has left many of its residents feeling anxious and off-balance. No, it’s not the smoke from all the...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

Episode #22 The Accidental Entrepreneur - The Optimal Corporate Set Up discusses the virtues and financial powers of creating your own business as a vehicle for ensuring your current and future financial stability. Consider...more

Gerald Nowotny - Law Office of Gerald R....

The Accidental Entrepreneur - Part II The Optimal Corporate Set Up

In April 2016, I wrote Part One of this series. You can read this article on JD Supra. Part One focused on the hobby loss tax rules. Four years later I am writing part two. Did I forget that I had written part one? Perhaps!...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Poyner Spruill LLP

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

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Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

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BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here to Stay: It’s Time to Act - Construction and Procurement Law News, Q2 2018

The January 1, 2018 effective date of the new federal partnership audit rules quietly came and went, with many of our partnership and LLC clients and their advisers hoping that the rules were just a bad dream or would at...more

Davis Wright Tremaine LLP

Sweeping Changes to Partnership Audit Rules Warrant Changes to Existing Partnership and LLC Agreements

Sweeping changes to the rules governing federal income tax audits of partnerships went into effect this year. The new partnership audit rules (the “New Audit Rules”) apply for partnership tax returns for taxable years...more

Verrill

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

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In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

Whitman Legal Solutions, LLC

If One Musician Plays A Wrong Note, the Entire Orchestra Now May Pay the Price -- Be Aware of New Partnership Tax Audit Rules

In 1985, the “participatory journalist” George Plimpton worked as a temporary percussionist, playing sleigh bells, triangle, bass drum, and most notably, gong, with the New York Philharmonic. During a performance, he once...more

Perkins Coie

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

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New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

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Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

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