News & Analysis as of

Pass-Through Entities

Tackling Tax Reform – Part IV: What Can We Expect To See

by Garvey Schubert Barer on

On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more

Oil & Gas Tax Alert - "Trump's 15% Pass Through Tax Proposal: Say Goodbye to Joint Operating Agreements?"

by Porter Hedges LLP on

On Wednesday, April 26, President Trump submitted his tax reform proposal which is, for now, only about 100 words long. It contemplates a number of sweeping changes to the tax code. On the business side, these include a 15%...more

Nate Smithson Provides an Update on Tax Reform

by Jackson Walker on

Jackson Walker partner Nate Smithson has prepared an updated guide to tax reform under the Trump administration. The guide covers tax brackets, deductions, capital gains, and other relevant topics in tax law. Please see...more

Have Yourself a Very Trumpy Tax Plan

by Dechert LLP on

Well, we’ve had the big reveal and the administration’s new tax plan is out. This plan, announced with a great deal of fanfare, feels more like a campaign promise than an actual executable plan. At two hundred forty-six...more

Business Tax Reform – the Current State of Play

by Ballard Spahr LLP on

President Donald J. Trump campaigned on a platform of large tax cuts for businesses. With President Trump in the White House and Republicans controlling both the House of Representatives and Senate, does it mean businesses...more

IRS Notice: Conservation Easements for Charitable Giving

by Bryan Cave on

In Notice 2017-10, the Internal Revenue Service recently issued guidance on syndicated conservation easement transactions presumed to be used as tax shelters. This addition to the “listed transactions” under Section...more

Tax Planning in Uncertain Times

by McNair Law Firm, P.A. on

There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the...more

New Filing Guidance for PTEs Participating in Rehabilitation Credit Projects

by Miles & Stockbridge P.C. on

In CCA 201641022 (October 7, 2016) (the “CCA”), the IRS issued new guidance regarding filing requirements for pass-through entities (“PTEs”) involved in rehabilitation credit projects. Under this new guidance, (1) a PTE may...more

Transmission Partnership Not Deemed Includible in Consolidated Return and Allowed To Collect Income Tax Allowance in its Rates

On January 6, 2017, Texas utility companies organized as pass-through entities, including partnerships, received welcome news regarding their ability (1) not to elect to be treated as a corporation eligible to be included in...more

Treasury and IRS Release Final Regulations on Qualifying Income, but Halted by Trump Moratorium

by Bracewell LLP on

January 25, 2017 On January 19, 2017, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding qualifying income under Internal Revenue Code (Code) section...more

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Global Private Equity Newsletter - Winter 2017 Edition: President Trump: The Outlook for Private Equity

by Dechert LLP on

All eyes are on Washington—or should we say Manhattan—these days, searching for clues about where our ship is heading with U.S. President-elect Donald Trump at the helm. Recently, there have been cabinet appointments to...more

Who Is The Taxpayer?

by Farrell Fritz, P.C. on

Back to Basics - This is not a silly question. In fact, it is often one of the most difficult issues confronted by a tax adviser, and it arises from one of the most basic of tax principles; specifically, that income is...more

IRS Rules That Syndicated Conservation Easements With Inflated Appraisals Are Listed Transactions

by McNair Law Firm, P.A. on

In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more

Is Tax Reform On the Horizon?

by Butler Snow LLP on

2017 will bring Republican control to D.C. It will also potentially bring tax reform. Both President Elect Donald Trump and House Republicans have proposed sweeping changes to the U.S. tax system, which we have briefly...more

Federal Contractors Be Aware: Rule on Tax Delinquencies and Felony Convictions Finalized

by Holland & Knight LLP on

The U.S. government finalized on Sept. 30, 2016, regulations amending the Federal Acquisition Regulation (FAR) that will affect an estimated 350,000 federal contractors. These new regulations were promulgated as a result of...more

Tax Tribunal Strikes Down Limitation on Credit for Taxes Paid to Other States

Readers may recall that Alabama Act 2012-427 permitted Alabama residents that owned interests in multistate pass-through entities (e.g., LLCs, partnerships, and S corporations) to claim a credit against their Alabama income...more

Manatt on Health Reform: Weekly Highlights - August 2016 #2

CMS targets Medicaid managed care pass-through payments; California proposes “California Qualified Health Plans” for the undocumented; and a new study finds out-of-pocket costs were reduced by nearly a third for Medicaid...more

IRS Issues Section 50(d) Guidance

by Lathrop & Gage LLP on

On July 22, 2016, the United States Department of Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued temporary Treasury Regulations (Temporary Regulations) related to the income inclusion rules under...more

DC Circuit Ruling Threatens to Topple FERC Tax Allowance Policy

by Morgan Lewis on

Court rules that FERC policy permitting a tax allowance for pass-through entities may unjustifiably permit “double-recovery” of tax expense. On July 1, the US Court of Appeals for the District of Columbia Circuit issued...more

DC Circuit Decision Likely to Reignite FERC Debate Over Tax Allowance for Pass-through Entities

by Cozen O'Connor on

The recent decision by the U.S. Court of Appeals for the District of Columbia Circuit in United Airlines Inc., et al., v. Federal Energy Regulatory, Case No. 11-1479, July 1, 2016 (United Airlines) will likely reignite a...more

A Short Summary of Qualified Small Business Stock Tax Benefits and Requirements

by DLA Piper on

Many startups, investors, clients and friends have recently asked about the tax benefits associated with having stock qualify as qualified small business stock (QSBS). This is an important issue that investors, founders and...more

Partnership Audit and Tax Collection Rules Undergo Fundamental Change

by Goodwin on

Under the default rule, any adjustment to partnership items or allocations among the partners will be determined, and any tax (including interest and penalties) attributable to adjustments will be collected, at the...more

New Partnership Audit Rules Heading Our Way?

The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited. Specifically, it would repeal the much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules....more

9th Circuit Disregards Purported Related-Party Partnership

by Goulston & Storrs PC on

In DJB Holding Corp. the 9th Circuit concluded that a purported related-party partnership was not a bona fide partnership for tax purposes and taxable income was redirected to the taxable C corporation performing the...more

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