News & Analysis as of

Section 199 Income Taxes

Farrell Fritz, P.C.

Timing The Sale Of A Business . . .To Maximize The Sec. 199A Deduction?

Farrell Fritz, P.C. on

Yes, it sounds odd. It is also seems to be at odds with this blog’s constant refrain of “Thou shalt not pursue any undertaking solely for tax purposes, but thou shalt first consider the business purpose for such...more

BakerHostetler

Final Pass-Through Regulations Issued Just in Time for Filing Season

BakerHostetler on

As discussed in our prior alert, the proposed Section 199A regulations provided welcome guidance regarding the application of the pass-through deduction across related entities but left many questions unanswered. ...more

BakerHostetler

IRS Provides Real Estate Rental Safe Harbor to Qualify for Pass-Through Deduction

BakerHostetler on

When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more

Farrell Fritz, P.C.

Rental Real Estate And The Sec. 199A Deduction: Round Two

Farrell Fritz, P.C. on

Shortly after Section 199A was added to the Code at the end of 2017, and again after the IRS proposed regulations under the newly-enacted provision last summer, many clients called us with the following question: “Will my...more

Farrell Fritz, P.C.

Trusts And The Section 199A Deduction

Farrell Fritz, P.C. on

If there was one part of the Tax Cuts and Jobs Act (“TCJA”) that estate planners were especially pleased to see, it was the increase in the basic exclusion amount from $5.49 million, in 2017, to $11.18 million for gifts made,...more

Bracewell LLP

Bracewell Tax Report - September 2018 #2

Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more

Farrell Fritz, P.C.

The Section 199A Deduction . . . And M&A?

Farrell Fritz, P.C. on

I realize that the last post began with “This is the fourth and final in a series of posts reviewing the recently proposed regulations (‘PR’) under Sec. 199A of the Code” – strictly speaking, it was. Yes, I know that the...more

Proskauer Rose LLP

Treasury and IRS Issue Proposed "Pass-Through Deduction" Regulations

Proskauer Rose LLP on

On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more

Holland & Knight LLP

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

Holland & Knight LLP on

Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

Lowndes

Republicans Announce Tax Reform Framework, Which Includes Repealing Estate Tax

Lowndes on

After months of speculation, President Trump and the Republicans have announced their framework for tax reform. While specific details are not known, the key elements of the framework include...more

Troutman Pepper

Recent Taxpayer-Friendly Section 199 Guidance On Benefits And Burdens Of Ownership

Troutman Pepper on

Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more

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