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Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Farrell Fritz, P.C.

The Loss Of The Favorable Capital Gain Rate, The Exclusion Of Gain under Section 1202, And The Incorporation Of The Partnership

Farrell Fritz, P.C. on

If the Democrats Win- Science has not established – at least to my knowledge – any correlation between the pre-election year-end activities of individual business owners, on the one hand, and election outcomes, on the...more

Farrell Fritz, P.C.

S’s, ESBT’s, NRA’s – AOK?

Farrell Fritz, P.C. on

Letters, acronyms, initialisms – they seem to slip into every post these days. It has always been a goal of U.S. tax policy to ensure that taxable income sourced in the U.S. does not escape the federal income tax....more

Mitchell, Williams, Selig, Gates & Woodyard,...

S Election Terminated as a Result of Form Operating Agreement Language

A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more

Farrell Fritz, P.C.

Current Distributions & Partial Liquidations: Corps vs. Partnerships

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“You Must Choose, But Choose Wisely.” The enactment of the Tax Cuts and Jobs Act, and its undeniable bias in favor of C corporations, has spurred the owners of many closely held businesses, along with their advisers, to...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

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Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Mintz Edge

LLCs and Convertible Debt – Too Good to be True?

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Founders choosing a structure for their business are often drawn to the limited liability company, or LLC, for its overall flexibility in both taxation and governance matters. And founders seeking access to early capital, not...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

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A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

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The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Williams Mullen

Interim Guidance Issued on New Business Interest Expense Limitations

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The IRS and the Treasury Department recently announced interim guidance to help taxpayers comply with the new business interest expense limitations under the Tax Cuts and Jobs Act (P.L. 115-97) (the “Act”). Notice 2018-28,...more

Verrill

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

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In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

Bracewell LLP

Bracewell Tax Report: March 2018

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

McDermott Will & Emery

Choices for Illinois Taxpayers in Implementing the 2017 Income Tax Rate Increase

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Last year, Illinois enacted a mid-year income tax rate increase. Effective July 1, 2017, Illinois increased the income tax rate for individuals, trusts and estates from 3.75 percent to 4.95 percent, and for corporations from...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

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Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“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

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

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On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

McDermott Will & Emery

The Impact of Tax Reform on Private Equity and M&A Transactions

Now that the 2017 tax reform act is law, private equity and M&A professionals must grapple with its sweeping changes and reconcile the new provisions with how they do business. This On the Subject summarizes important...more

Mitchell, Williams, Selig, Gates & Woodyard,...

What Practitioners Need to Know about the New Partnership Audit Rules

As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more

Farrell Fritz, P.C.

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

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Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Farrell Fritz, P.C.

When Investing In A Partnership May Be A Tax Problem

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A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Miller Canfield

Summary of IC-DISC Tax Benefits

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Interest-Charge Domestic International Sales Corporations (“IC-DISCs”) offer significant potential tax benefits for U.S. companies that export U.S. manufactured products or certain engineering or architectural services with...more

Gerald Nowotny - Law Office of Gerald R....

For Love or Charity – A Charitable Bailout Using Charitable Remainder Trusts for the Sale of a C Corporation

I have personally observed in my professional travels that many taxpayers are reluctant charitable donors. However, we you remind a business owner that they only have three choices when it comes to taxes (1) Pay yourself;...more

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