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C-Corporation Income Taxes Partnerships

Allen Barron, Inc.

It’s Time to Start Making Estimated Tax Payments Again California

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The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

J.S. Held

Don’t Double Tax Your Business: How The PTE Tax Can Impact the Valuation of Pass-Through Entities

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Taxes can have a significant impact on the value of a business. Pass-through entities such as S-Corporations and partnerships generally do not pay any taxes since the income is passed through to the individual shareholder or...more

Holland & Knight LLP

Commuting Disallowance in 274(l) Does Not Apply to Partners, 2% Shareholders in S Corporations

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Beginning in 2018, Internal Revenue Code (I.R.C.) Section 274(l) disallows deductions for the cost of flights provided to an "employee" for commuting. While this deduction disallowance may apply to employees of Subchapter C...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

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Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

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Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...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

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

Poyner Spruill LLP

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

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Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

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On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...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

Burr & Forman

New IRS Proposed 199A Regulations Provide Guidance on 20% Profit Pass-Through Deduction

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On August 8th, the IRS released its much-awaited Proposed Regulations on the new Section 199A 20% profit deduction for pass-through businesses. The new deduction applies to essentially all types of businesses other than C...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

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

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Manufacturing, Distribution and Retail 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

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

Baker Donelson

FBAR Deadlines Not as Close as You Think: New Tax Bill's Language Points to 2017 as Likely Timetable

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Thank you for your interest in the 5th Annual IRS Hot Topic Seminar held in Jerusalem in July. In continuing our efforts to provide timely and extremely important updates on tax matters affecting U.S. citizens and green card...more

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