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
BACKGROUND -
Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
1/8/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Qualified Opportunity Funds ,
Real Estate Development ,
State and Local Government ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
U.S. Treasury
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
“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest.
BACKGROUND/PRIOR LAW -
Interest...more
2/7/2018
/ Borrowers ,
Business Expenses ,
Business Taxes ,
C-Corporation ,
Carry Forward ,
Carve Out Provisions ,
Corporate Taxes ,
Debt ,
EBITDA ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Lenders ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
S-Corporation ,
Shareholders ,
Small Business ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Taxable Income ,
Termination
BACKGROUND/PRIOR LAW -
PartnershipUnder IRC § 708(a), a partnership is considered as a continuing entity for income tax purposes unless it is terminated. Given the proliferation of state law entities taxed as partnerships...more
1/23/2018
/ Business Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Limited Liability Partnerships ,
Mergers ,
Partnerships ,
Repeal ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax Reform ,
Termination ,
Trump Administration