Like other commentators, we have been writing extensively about the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), the historic $2.2 trillion relief package enacted last month by lawmakers in the wake...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
As we have been discussing these past several weeks, the Tax Cuts and Jobs Act (“TCJA”) drastically changed the Federal income tax landscape. The TCJA also triggered a sea of change in the income tax laws of states like...more
The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”).
Virtually none of...more
4/9/2018
/ Acquisitions ,
Alternative Minimum Tax ,
Commercial Real Estate Market ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
International Tax Issues ,
Mergers ,
Net Operating Losses ,
S-Corporation ,
Section 1031 Exchange ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
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
The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more
3/9/2018
/ Alimony ,
Alternative Minimum Tax ,
Child Tax Credit ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Local Taxes ,
Medical Expenses ,
Mortgage Interest ,
Personal Exemptions ,
Standard Deduction ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Refunds ,
Trump Administration
BACKGROUND -
The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more
2/28/2018
/ Affordable Care Act ,
Compensation & Benefits ,
Covered Employees ,
Deferred Compensation ,
Employee Relocations ,
Fringe Benefits ,
Income Taxes ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
IRS ,
Meal and Entertainment Expenditures ,
Medical Leave ,
Paid Family Leave Law ,
Pre-Employment Agreements ,
Repeal ,
Tax Benefits ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Transportation Costs ,
Trump Administration
“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 -
The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more
1/30/2018
/ Business Income ,
Business Taxes ,
C-Corporation ,
Compensation ,
Deduction Limitations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Landlords ,
Limited Liability Company (LLC) ,
Pass-Through Entities ,
Property Owners ,
S-Corporation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Penalties ,
Tax Reform ,
Threshold Requirements ,
Trump Administration ,
W-2 ,
Wage and Hour
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
BACKGROUND -
On February 21, 2014, then House Ways and Means Committee Chairman Dave Camp (R-Michigan) issued a discussion draft of the “Tax Reform Act of 2014.” The proposed legislation spanned almost 1,000 pages and...more
As indicated at the end of 2017, I intend to provide our readers with an in-depth review of the Tax Cuts and Jobs Act (“TCJA”). With the help of two of my colleagues, Steven Nofziger and Miriam Korngold, we will do this in a...more