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
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
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
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
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
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
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
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
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
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
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