News & Analysis as of

Trusts Pass-Through Entities

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

Williams Mullen

Tax Planning Opportunity for Owners of Pass-Through Entities: Virginia Enacts Workaround to $10,000 Federal Income Tax Limitation...

Williams Mullen on

Virginia recently enacted legislation that provides an opportunity for the owners of a qualified pass-through entity (PTE) to reduce their federal income tax liability if the PTE makes an election to pay Virginia taxes at the...more

Cole Schotz

Nelson: IRS Prevails In Defined Value Provision Case

Cole Schotz on

On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets. The taxpayer’s...more

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

Burr & Forman on

On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Burr & Forman

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

Burr & Forman on

Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Dentons

Section 199A and Calculating and Reporting for Relevant Passthrough Entities, Publicly Traded Partnerships, Trusts, and Estates

Dentons on

Last week, we provided a high-level overview on the application of Section 199A as it relates to estates, trusts, and beneficiaries. This post will cover the details of calculating and reporting the Section 199A deductions....more

Burr & Forman

New IRS Proposed 199A Regulations Provide Guidance on 20% Profit Pass-Through Deduction

Burr & Forman on

On August 8th, the IRS released its much-awaited Proposed Regulations on the new Section 199A 20% profit deduction for pass-through businesses. The new deduction applies to essentially all types of businesses other than C...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of New US Tax Law on High Net Worth Individuals, Trusts and Family Offices

The newly enacted U.S. tax law makes significant changes to provisions of the Internal Revenue Code affecting high net worth individuals, their investment entities and family offices. These changes are likely to spur gift...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Burr & Forman

New Internal Revenue Code Section 199A: The 20% Deduction for “Pass-Thru” Businesses

Burr & Forman on

Aside from corporate tax reductions, one of the most important aspects of the new Tax Cuts and Jobs Act beginning this year is the new 20% deduction for “pass-thru” businesses – i.e. businesses that are not corporations. With...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Lowndes

New Partnership Audit Rules Heading Our Way?

Lowndes on

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

McNees Wallace & Nurick LLC

Pass-Through Business Tax Alert

The Pennsylvania Department of Revenue has announced that it will soon begin identifying pass-through business entities that have under-reported income, failed to file PA-20S/PA-65 Information Returns, and failed to maintain...more

Troutman Pepper

In Frank Aragona Trust, Tax Court Holds that Trustees’ Activities as Employees Count for Purposes of Material Participation Under...

Troutman Pepper on

The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more

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