On July 27, the Senate reached a deal that would raise taxes on carried interest income earned by investment managers. If enacted, the Inflation Reduction Act of 2022 (the “Act”) would amend the relatively new Section 1061...more
The Organisation for Economic Co-operation and Development (the “OECD”) recently announced that a landmark deal has been reached by 136 countries in an attempt to ensure that Multinational Enterprises (“MNEs”) are subject to...more
This newsletter was updated March 25 to reflect new information released by the IRS. On March 21, 2020, the IRS released IRS Notice 2020-58, which replaces all earlier announcements concerning extended deadlines discussed in...more
This newsletter was updated March 19 to reflect new information released by the IRS. The IRS has now released IRS Notice 2020-17 which clarifies some issues concerning the 90-day extension discussed in our previous alert...more
The IRS has released the long-awaited final regulations on the Section 199A qualified business income deduction. Along with the regulations, the IRS released Notice 2019-07 that contains a proposed revenue procedure with a...more
The IRS and Treasury have released proposed regulations under newly-enacted Internal Revenue Code Section 199A, which creates a deduction for qualified business income that non-corporate taxpayers receive from passthrough...more
The IRS and Treasury have released proposed regulations concerning the first-year bonus depreciation deduction, also known as immediate expensing. The proposed regulations reflect changes made to bonus depreciation rules by...more
Last week, the US Tax Court issued a summary opinion holding that a taxpayer could not exclude settlement proceeds from gross income because the settlement agreement failed to contain any reference to physical injuries....more
On April 2, the Treasury and the IRS issued Notice 2018-28 which provides guidance concerning the business interest expense limitation enacted as part of tax reform. The guidance includes the application of the rules to...more
On March 1, the IRS and Treasury announced their intent to issue regulations addressing the new carried interest rules enacted as part of tax reform. More specifically, they intend to clarify that the new rules apply to...more
The U.S. Supreme Court has agreed to hear South Dakota v. Wayfair, Inc. (“Wayfair”). Its decision has the potential to change the way online retailers and other remote vendors do business by permitting states to collect sales...more
Prior to tax reform, tax considerations tipped the scale heavily in favor of operating a business through a partnership or other pass-through entity rather than a corporation. Now that the corporate income tax rate has been...more
On December 15, 2017, the House and Senate conferees released a final version of the Tax Cuts & Jobs Act. Votes for passage of the bill are intended to take place in the House on Tuesday, December 19, 2017 and in the Senate...more
12/20/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Child Tax Credit ,
Corporate Taxes ,
Estate Tax ,
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Tax Deductions ,
Tax Exempt Entities ,
Tax Rates ,
Tax Reform
On November 2, 2017, the House Republicans released their long-awaited tax reform bill, the Tax Cuts & Jobs Act. If the bill becomes law, it will mark the most significant change to the Tax Code in thirty years. The bill...more
On September 27, 2017, the White House Administration and Republican leadership came together to release the highly-anticipated "Big Six" tax framework for tax reform. The 9-page outline provides few details and mimics...more
On July 20, 2017, the Internal Revenue Service ("IRS") issued a reminder for small businesses on the importance of correctly classifying workers as employees or independent contractors. Employers failing to do this correctly...more
A recent ruling from the IRS should serve as a warning to employers that hire professional employer organizations ("PEO") to manage payroll: the employer may still be liable for any failures to report and pay over employment...more
Taxpayers may no longer need to be concerned with the 3.8% Net Investment Income Tax, among other taxes established under the Affordable Care Act ("ACA"). On March 6, 2017, the House Ways and Means Republicans unveiled the...more
President Trump recently indicated that he will announce a tax reform proposal within the next two to three weeks. The existing tax proposals from President Trump and the Congressional Republicans are predictably vague at...more
A federal tax issue frequently arises when key employees of an operating business are given the opportunity to become equity holders. Despite the well-established rule that partners of a partnership are not permitted to be...more