News & Analysis as of September 25, 2024

Section 199

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Timing The Sale Of A Business . . .To Maximize The Sec. 199A Deduction?

Farrell Fritz, P.C. on 2/25/2019

Yes, it sounds odd. It is also seems to be at odds with this blog’s constant refrain of “Thou shalt not pursue any undertaking solely for tax purposes, but thou shalt first consider the business purpose for such...more

Final Pass-Through Regulations Issued Just in Time for Filing Season

BakerHostetler on 1/31/2019

As discussed in our prior alert, the proposed Section 199A regulations provided welcome guidance regarding the application of the pass-through deduction across related entities but left many questions unanswered. ...more

IRS Provides Real Estate Rental Safe Harbor to Qualify for Pass-Through Deduction

BakerHostetler on 1/31/2019

When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more

Bracewell Tax Report - September 2018 #2

Bracewell LLP on 9/20/2018

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, with emphasis on how such developments impact the energy, technology...more

Treasury and IRS Issue Proposed "Pass-Through Deduction" Regulations

Proskauer Rose LLP on 8/24/2018

On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

Holland & Knight LLP on 12/20/2017

Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

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