News & Analysis as of

Pass-Through Entities Tax Rates

Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more

Baker Donelson

SALT Select Developments - May 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

PilieroMazza PLLC

Focus on S Corporations, Part 2: Inadvertent Termination of S Corporation Elections

PilieroMazza PLLC on

The IRS recently provided guidance addressing inadvertent terminations of S Corporation (S Corp) status based on existing provisions in corporate documents that remain after a company makes an S Corp election. This can be a...more

Burns & Levinson LLP

VAS Holdings v. Commissioner of Revenue - Taxing Out-of-State Entities on the Sale of a Massachusetts Business

Burns & Levinson LLP on

What Was At Stake - At issue in a recent, significant tax decision of the Supreme Judicial Court (“SJC”) was whether the Massachusetts Commissioner of Revenue could tax an out-of-state shareholder on the gains it derived...more

Baker Donelson

SALT Select Developments - April 2022

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

BakerHostetler

[Podcast] Phasing Out Corporate Income Taxes - North Carolina Edition

BakerHostetler on

Matt Hunsaker discusses recent North Carolina tax legislation, including phase-out/phase-down of corporate and individual income tax rates, an elective passthrough entity SALT cap workaround, and simplification of the...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

Foster Garvey PC on

Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

McGuireWoods LLP

Build Back Better Act: House Ways and Means Committee Tax Proposals – Key Issues for Corporations, Passthrough Entities, and...

McGuireWoods LLP on

On Sept. 15, 2021, the Ways and Means Committee of the U.S. House of Representatives approved a proposed tax legislative package (the “W&M proposal”) to the Build Back Better Act reconciliation bill (the “Act”), which...more

Eversheds Sutherland (US) LLP

Department of Taxation and Finance releases long awaited guidance addressing pass-through entity tax

On August 25, 2021, the New York State Department of Taxation and Finance released guidance (Technical Memorandum, TSB-M-21(1)C, (1)I) addressing the recently enacted optional pass-through entity tax (PTET) that partnerships...more

Kilpatrick

4 Key Takeaways | Mid-Year Tax Update

Kilpatrick on

On June 22, 2021, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the...more

Bowditch & Dewey

Massachusetts Legislature Passes Legislation Enacting Work Around to Federal $10,000 SALT Deduction Limitation, but Governor Baker...

Bowditch & Dewey on

On July 16, 2021, Governor Baker approved a $47.6 billion fiscal 2022 budget, but sent back a provision the Massachusetts Legislature passed creating a workaround for the federal cap on the state and local tax deduction. ...more

Kilpatrick

4 KEY TAKEAWAYS: Mid-Year Tax Update

Kilpatrick on

On June 22nd, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the federal...more

Rivkin Radler LLP

Tax Increases In Sight? Time To Sell The Business? Focus On Economics

Rivkin Radler LLP on

Not Good- As Mr. Biden settled into the White House, and as the Democrats began planning how to best utilize their slim Congressional majority to enact and pay for their sweeping legislative agenda, the principal concern...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Kelley Drye & Warren LLP

New York State Enacts Elective Pass-through Entity Tax as a SALT Deduction Limitation Workaround

In April 2021, New York State enacted legislation providing for a new elective pass-through entity (PTE) tax on partnerships and Subchapter S corporations. The 2017 Tax Cuts and Jobs Act generally limits an individual’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...more

Blank Rome LLP

New York State Enacts Pass-Through Entity Tax as SALT Limitation Workaround

Blank Rome LLP on

On April 19, 2021, New York Governor Andrew Cuomo signed into law legislation that creates a New York Pass-Through Entity Tax, effective for tax years beginning on or after January 1, 2021. This consequential tax legislation,...more

Eversheds Sutherland (US) LLP

Georgia’s 2021 Sine Die - Thoughtful policy mixed with last minute surprises and everything in-between

During the 2021 legislative session, the Georgia General Assembly passed key legislation, including conformity to the federal tax law, the elimination of deference to subregulatory interpretations of the Department of...more

Burr & Forman

South Carolina May Join Other States to Provide State and Local Tax Cap Workaround

Burr & Forman on

The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a $10,000 cap on the federal deduction for state and local taxes for tax years 2018-2025.  While corporations are not subject to the cap, business owners who pay state and...more

Farrell Fritz, P.C.

The Loss Of The Favorable Capital Gain Rate, The Exclusion Of Gain under Section 1202, And The Incorporation Of The Partnership

Farrell Fritz, P.C. on

If the Democrats Win- Science has not established – at least to my knowledge – any correlation between the pre-election year-end activities of individual business owners, on the one hand, and election outcomes, on the...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

Bradley Arant Boult Cummings LLP

Legislative Task Force on the Impact of the Tax Cuts and Jobs Act Releases Its Final Report - SALT Alert: Alabama Edition

The Alabama Legislature was stymied last year over proposals to decouple from or conform with various provisions of the Tax Cuts and Jobs Act of 2017 (TCJA). As a compromise, the Legislature formed a Joint Legislative Task...more

Morgan Lewis

NJ Enacts Elective Pass-Through Business Tax to Limit Federal Cap Impact on SALT Deduction

Morgan Lewis on

New Jersey recently enacted the “Pass-Through Business Alternative Income Tax Act,” which allows pass-through businesses with at least one member liable for the New Jersey gross income tax to make an election to pay income...more

Troutman Pepper

Choice of Entity Considerations Post-Tax Reform: Corporation or Flow-Through Entity?

Troutman Pepper on

Choosing the appropriate type of entity is a multifaceted analysis and is necessarily dependent upon a variety of factors, including business objectives, type of business, desire for cash distributions, and ease of obtaining...more

191 Results
 / 
View per page
Page: of 8

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide