This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more
Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more
11/3/2021
/ Business Taxes ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Local Taxes ,
Oregon ,
Partnerships ,
Pass-Through Entities ,
S-Corporation ,
SALT ,
State and Local Government ,
State Taxes ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Rates
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code.
Tax legislation is...more
10/15/2021
/ Asset Valuations ,
Biden Administration ,
Business Losses ,
Business Taxes ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Contribution Limits ,
Corporate Taxes ,
Death Tax ,
Estate Planning ,
Estate Tax ,
Estate-Tax Exemption ,
Federal Taxes ,
Gift Tax ,
Gifts ,
High Net-Worth ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Investment Income ,
Partnership Interests ,
Pending Legislation ,
Qualified Business Income ,
Qualified Small Business Stock ,
Required Minimum Distributions ,
Retirement Plan ,
Tax Deductions ,
Tax Exemptions ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trusts
It is not unreasonable to anticipate that there will be a federal tax policy transformation following a change in the political control of the White House, the U.S. Senate and the U.S. House of Representatives. What may be...more
2/25/2021
/ Business Taxes ,
Capital Gains Tax ,
Corporate Taxes ,
Federal Taxes ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Section 1031 ,
Tax Liability ,
Tax Planning ,
Tax Policy ,
Tax Rates
The Consolidated Appropriations Act, 2021 -
In a bipartisan effort, H.R. 133-116th Congress: Consolidated Appropriations Act, 2021 (the "Consolidated Appropriations Act, 2021") overwhelmingly passed both the House and the...more
12/23/2020
/ Business Expenses ,
Business Taxes ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Debt ,
Federal Taxes ,
Income Taxes ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Pending Legislation ,
Tax Deductions ,
Tax Relief ,
Trump Administration
As we reported last week, the Oregon Department of Revenue (“DOR”) scheduled a public hearing on June 23, 2020 to discuss the second set of temporary administrative rules relative to the Oregon Corporate Activity Tax (the...more
6/26/2020
/ Agricultural Sector ,
Business Taxes ,
Commercial Activity Tax ,
Department of Revenue ,
Exclusions ,
Grocery Stores ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Out-of-State Companies ,
Rulemaking Process ,
State Taxes ,
Tax Planning ,
Wholesale
The Oregon Department of Revenue (“DOR”) announced that it will be conducting a public hearing on June 23, 2020 to discuss a second set of temporary administrative rules relative to the Oregon Commercial Activity Tax (the...more
As we recently reported, the Oregon Department of Revenue (“ODOR”) issued written guidance concluding that the receipt of funds pursuant to PPP loans (whether or not forgiven), EIDLP advances and SBA debt relief for certain...more
5/19/2020
/ B&O Tax ,
Business Taxes ,
Commercial Activity Tax ,
Coronavirus/COVID-19 ,
Debt Relief ,
Department of Revenue ,
Economic Injury Disaster Loans ,
Paycheck Protection Program (PPP) ,
SBA ,
State Taxes ,
Tax Deductions ,
Tax Liability ,
Tax Planning
I hope our readers, their families and co-workers are safe and remain healthy during these trying times. As a distraction for tax geeks like us from the news about the Coronavirus that is permeating our lives these days,...more
3/19/2020
/ Business Taxes ,
Commercial Activity Tax ,
Compensation ,
Corporate Taxes ,
Department of Revenue ,
Exclusions ,
Income Taxes ,
Independent Contractors ,
Rulemaking Process ,
State Taxes ,
Subcontractors ,
Tax Planning
Temporary Rules Keep Rolling in -
The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more
2/27/2020
/ Business Taxes ,
Car Dealerships ,
Commercial Activity Tax ,
Corporate Taxes ,
Documentation ,
Exclusions ,
Grocery Stores ,
Income Taxes ,
Motor Vehicles ,
New Guidance ,
Out-of-State Companies ,
Retailers ,
Safe Harbors ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Wholesale
The CAT Tour -
As previously discussed, late last year, the Oregon Department of Revenue (the “Department”) conducted several town hall meetings with taxpayers and tax practitioners across the state to discuss the...more
A dog will immediately respond to you when you call out. On the other hand, when you call out to a cat, the cat will take a message and promise to get back to you later. This is not the case with the Corporate Activity Tax...more
On January 6, I presented a new White Paper, The Oregon Corporate Activity Tax – You Can Run and You Can Hide, but This New Tax Is Effective January 1, 2020, at the Oregon Society of Certified Public Accountants Annual State...more
Recent Announcements -
The Oregon Department of Revenue (the “Department”) has made several recent announcements regarding Oregon’s new Commercial Activity Tax (the “CAT”).
In an email dated December 4, 2019, the...more
12/20/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Income Taxes ,
New Rules ,
State Taxes ,
Substantial Nexus ,
Tax Liability ,
Tax Planning ,
Underpayment
In recent months, we have written extensively about Oregon’s new Corporate Activity Tax (the “CAT”). As discussed in our last post, the Oregon Department of Revenue (the “Department”) recently announced that it would hold a...more
We have written at length about Oregon’s new Corporate Activity Tax (the “CAT”). As discussed in our last post, the Oregon Department of Revenue (the “Department”) recently concluded a series of 12 town hall meetings around...more
We have been covering Oregon’s new Corporate Activity Tax (the “CAT”) over the past few months. As previously discussed, the Oregon Department of Revenue (the “Department”) has been conducting town hall meetings with...more
10/10/2019
/ Business Taxes ,
Corporate Taxes ,
Department of Revenue ,
Electronic Filing ,
Income Taxes ,
New Rules ,
Rulemaking Process ,
State Taxes ,
Tax Planning ,
Temporary Regulations ,
Town Hall Meetings
What We Learned from one of the Oregon Department of Revenue’s Town Hall Meetings -
Over the past few months, we have written extensively on the blog about Oregon’s new Corporate Activity Tax (the “CAT”). As announced in...more
10/3/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Exceptions ,
Grocery Stores ,
Income Taxes ,
Legislative Agendas ,
Registration Requirement ,
Regulatory Agenda ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Wholesale
We have recently discussed in several blog posts Oregon’s new Corporate Activity Tax (“CAT”), a gross receipts tax that will become effective January 1, 2020. As we announced in our most recent post on this topic, the Oregon...more
As discussed in recent blog posts, the Oregon Legislative Assembly recently enacted a Corporate Activity Tax (“CAT”). Governor Kate Brown signed the legislation into law, effective January 1, 2020. Put in simplest terms, the...more
As we reported in our June 4 blog post, Oregon lawmakers had recently enacted a “corporate activity tax” (“CAT”) that applies to certain Oregon businesses. The new law, absent challenge, becomes effective January 1, 2020.
We...more
7/26/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Governor Brown ,
Income Taxes ,
New Legislation ,
Referendums ,
Repeal ,
State Taxes ,
Tax Legislation ,
Tax Planning
Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more
We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation.
On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more
6/5/2019
/ Business Ownership ,
Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Goods or Services ,
Governor Brown ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Local Taxes ,
New Legislation ,
Popular ,
Referendums ,
Registration Requirement ,
Sales & Use Tax ,
State and Local Government ,
State Taxes ,
Substantial Nexus ,
Tax Legislation ,
Tax Planning ,
Tax Rates ,
Tax Returns ,
Tax Revenues ,
Underpayment ,
Unitary Business
The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more
8/9/2018
/ Anti-Abuse Rule ,
Business Income ,
Business Ownership ,
Business Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
S-Corporation ,
Sole Proprietorship ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
3/28/2018
/ Business Taxes ,
Charitable Donations ,
Charitable Organizations ,
Colleges ,
Endowment Funds ,
Estate Tax ,
Excise Tax ,
Executive Compensation ,
Fringe Benefits ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Standard Deduction ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Universities ,
Unrelated Business Income Tax