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Corporate Taxes Tax Deductions Tax Cuts and Jobs Act

Allen Barron, Inc.

How Does the TCJA Sunset Affect Business Taxation Going Forward

Allen Barron, Inc. on

The 2017 Tax Cuts and Jobs Act or TCJA has a number of important segments presently scheduled to expire on December 31, 2025. How does the TCJA sunset affect business taxation going forward? What planning could be...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Miller Nash LLP

Today in Tax: Eligibility of Electronic Services Income for FDII Deduction

Miller Nash LLP on

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Regulations open door for cloud computing, streaming, and related electronic services to be included in deduction computation....more

Freeman Law

The Claim-of-Right Doctrine & Section 1341

Freeman Law on

The U.S. Congress passed the Tax Cuts and Jobs Act (TCJA) in late 2017, substantially overhauling the Internal Revenue Code of 1986. The TCJA highlighted the importance of several often-overlooked provisions in the Tax Code....more

Nutter McClennen & Fish LLP

Overriding the Governor, Massachusetts Legislature Gives Pass-Through Entity Owners a Workaround to Federal SALT Deduction Cap

The Massachusetts legislature, overriding Governor Baker’s prior veto, has voted to enact a new elective pass-through entity (“PTE”) tax designed as a way for PTE owners to get out from under the $10,000 cap ($5,000 for...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for International Operations

Bowditch & Dewey on

In this final blog post on the House Ways and Means Tax Bill, we address the international tax proposals in the Bill, JCX-43-21. The international tax proposals are fewer in number than the domestic and transfer tax...more

Eversheds Sutherland (US) LLP

The devil is in the details: Final infrastructure framework announced, fingers crossed for continued R&E deductibility

Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more

Cadwalader, Wickersham & Taft LLP

Wyden Proposes Expansion of Pass-Through Deduction

On July 20, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) proposed legislation to modify the 20% deduction allowed to investors in certain pass-through businesses under Section 199A....more

Skadden, Arps, Slate, Meagher & Flom LLP

Biden Administration’s Green Book Proposes Significant Changes to Tax Regime

On May 28, 2021, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for FY...more

Blank Rome LLP

New York State Enacts Pass-Through Entity Tax as SALT Limitation Workaround

Blank Rome LLP on

On April 19, 2021, New York Governor Andrew Cuomo signed into law legislation that creates a New York Pass-Through Entity Tax, effective for tax years beginning on or after January 1, 2021. This consequential tax legislation,...more

Burr & Forman

South Carolina May Join Other States to Provide State and Local Tax Cap Workaround

Burr & Forman on

The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a $10,000 cap on the federal deduction for state and local taxes for tax years 2018-2025.  While corporations are not subject to the cap, business owners who pay state and...more

BakerHostetler

Preparing for Biden Administration Tax Changes

BakerHostetler on

With expected passage in the next few weeks of the Biden Administration’s first COVID-19 relief bill, the focus in Washington, D.C., will shift to a second budget reconciliation bill – Biden Administration tax changes. The...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Final Regulations Regarding Certain Employee Remuneration in Excess of $1 Million Under Section 162(m) of the Code

Section 162(m) of the Internal Revenue Code of 1986 (as amended, the “Code”) imposes a $1 million deductibility limit on compensation paid by “publicly held corporations” to “covered employees.” As reported in our previous...more

Katten Muchin Rosenman LLP

2020 Year-End Estate Planning Advisory

In 2020, COVID-19, the US presidential election, the Tax Cuts and Jobs Act (the TCJA), and the Coronavirus Aid, Relief and Economic Security Act (the CARES ACT) dominated the planning landscape....more

Wyrick Robbins Yates & Ponton LLP

Nine Biden Tax Proposals to Know as We Near Election Day

We’re roughly a month from Election Day, and I think it’s safe to say many Americans have strong opinions about who should be our President for the next four years.  I also think it’s safe to say taxes are not the top...more

Dorsey & Whitney LLP

Covid-19 Tax Relief Makes Winners out of Losses (for some)

Dorsey & Whitney LLP on

The CARES Act, signed into law on March 27, 2020 in the wake of the onset of the Covid-19 pandemic, contained numerous changes to U.S. federal income tax law. One such change applied to the deductibility of net operating...more

Skadden, Arps, Slate, Meagher & Flom LLP

Highlights From the Recently Issued Proposed Regulations Under Sections 162(f) and 6050X

On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more

Eversheds Sutherland (US) LLP

Whose Loss Is it Anyway? Losses in M&A after the CARES Act

Net operating losses (NOLs) of a corporation are often one of its most significant tax attributes and may be a meaningful economic driver in a disposition of the corporation or its assets. The Tax Cuts and Jobs Act (the TCJA)...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

Seyfarth Shaw LLP on

On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

Holland & Knight LLP

Proposed 162(m) Regulations Add Another Layer of Executive Compensation Issues in M&A

Holland & Knight LLP on

The Tax Cuts and Jobs Act of 2017 (TCJA) upended public company compensation structures nationwide. Prior to the TCJA, Section 162(m) of the Internal Revenue Code of 1986, as amended, generally provided for a $1 million...more

White and Williams LLP

Proposed Regulations Broaden Limitation on Compensation Deductions for Public Companies

White and Williams LLP on

Internal Revenue Code Section 162(m) generally limits the amount of compensation to certain individuals (Covered Individuals) that a publicly traded company may deduct as a business expense. The Tax Cuts and Jobs Act (TCJA)...more

Troutman Pepper

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

Kramer Levin Naftalis & Frankel LLP

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

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