Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more
On April 27, 2021, the Multistate Tax Commission (MTC) Uniformity Committee voted to accept its Standing Subcommittee’s recommendation to create a work group to study several key issues relating to multistate taxation of...more
As we noted in our previous SALT Alert, on October 1 the Alabama Department of Revenue (ADOR) quietly posted a notice on its website and shared it with media outlets that received little notoriety – at least initially. The...more
Retired Navy SEALs apparently have a persistence that other taxpayers may not have. Case in point (literally)—Noell Industries, Inc. v. Idaho State Tax Commission, decided on May 22, 2020, by the Idaho Supreme...more
On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more
12/19/2019
/ C-Corporation ,
Charitable Donations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Pass-Through Entities ,
Popular ,
Proposed Regulation ,
PTEs ,
S-Corporation ,
Safe Harbors ,
SALT ,
Scholarship Granting Organizations (SGOs) ,
State Taxes ,
Tax Credits ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more
1/4/2019
/ C-Corporation ,
Charitable Donations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Pass-Through Entities ,
Proposed Regulation ,
PTEs ,
S-Corporation ,
Safe Harbors ,
SALT ,
Scholarship Granting Organizations (SGOs) ,
State Taxes ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
U.S. Treasury
In a case of first impression by an Alabama appellate court, the Alabama Court of Civil Appeals recently considered the appeal of the Alabama Department of Revenue (ADOR) of an adverse circuit court ruling involving whether...more
9/14/2018
/ Appeals ,
Business Taxes ,
Check the Box Rules ,
Department of Revenue ,
Income Taxes ,
Limited Liability Company (LLC) ,
Sales & Use Tax ,
SALT ,
Standing ,
Tax Assessment ,
Tax Tribunal
The January 1, 2018 effective date of the new federal partnership audit rules quietly came and went, with many of our partnership and LLC clients and their advisers hoping that the rules were just a bad dream or would at...more
7/19/2018
/ Audits ,
C-Corporation ,
Construction Industry ,
IRS ,
Joint Venture ,
Limited Liability Company (LLC) ,
New Rules ,
Opt-Outs ,
Partnerships ,
S-Corporation ,
Tax Returns
Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more
10/19/2017
/ Appeals ,
Business Ownership ,
Business Privilege Tax ,
Business Taxes ,
Family Businesses ,
Family Limited Liability Companies ,
Family Limited Partnerships ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Tax Planning ,
Tax Returns ,
Wealth Management
The January 1, 2018 effective date of the new federal partnership audit rules is almost here, and we encourage all entities taxed as partnerships to consider addressing the issues posed by these new rules as soon as possible....more
The U.S. Treasury Department and the Internal Revenue Service (“IRS”) recently reissued 277 pages of proposed regulations and a preamble (REG-136118-15) regarding the new centralized partnership audit rules enacted as part of...more
The ADOR has proposed a number of amendments to its rule governing the filing of partnership tax returns, Form 65. The new rule, as proposed, inserts language conforming with Alabama’s recently enacted “factor presence nexus”...more
You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The IRS will be ramping up its...more
You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The new rules apply to tax years...more
The 2014 regular session of the Alabama legislature has been underway for over two months and is nearing its end. The legislature is off this week for Spring Break, then returns on Tuesday, April 1, for three final meeting...more
3/25/2014
/ Ad Valorem Tax ,
Audits ,
Business Privilege Tax ,
Education Budget ,
Income Taxes ,
Innocent Spouse Exception ,
Job Creation ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Net Operating Losses ,
Research and Development ,
Sales & Use Tax ,
State Budgets ,
Tax Assessment ,
Tax Credits
In This Issue:
- Nonresident Owner Nexus
- Apportionment of Multistate Income
- Entity-Level Income Tax Withholding
- Composite Returns
- Entity-Level Taxes
- Issues Unique to S...more
6/19/2013
/ Apportionment ,
Due Process ,
Income Taxes ,
Limited Liability Company (LLC) ,
Nexus ,
Non-Resident Aliens ,
S-Corporation ,
Sales & Use Tax ,
Shareholders ,
Tax Rates ,
Withholding Tax