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Income Taxes › Pass-Through Entities › Internal Revenue Service

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... more +
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 -
Allen Barron, Inc.

California and IRS Extended Income Tax Deadlines are Rapidly Approaching

Allen Barron, Inc. on

The California and IRS extended income tax deadlines are rapidly approaching as we near the deadline in mid-October.  In the first few months of 2023 California and the IRS extended income tax deadlines and associated...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Makes Permanent Its Fast-Track Corporate Private Letter Rulings

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On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more

Bradley Arant Boult Cummings LLP

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

Bradley Arant Boult Cummings LLP on

In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

Polsinelli on

After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Fox Rothschild LLP

Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases

Fox Rothschild LLP on

On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by...more

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

Sands Anderson PC on

Elective PTE Income Taxes Payable to Virginia - Beginning July 1, 2022, Virginia’s new law establishing a workaround for the federal income tax limitation on deductions for state and local taxes (SALT) became effective....more

Bradley Arant Boult Cummings LLP

ADOR Grants Extension to Make PTE Tax Election for 2021 Tax Year

Bradley Arant Boult Cummings LLP on

Readers may recall that the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) last year as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Income Tax – Ohio Jumps on Trend to Codify SALT Deduction Cap Workaround

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Last year, a post explained that investors in Ohio pass-through entities (PTEs) may be able to avoid the $10,000 state and local tax (SALT) deduction cap using Ohio’s composite return election. Now a little over a year later,...more

Baker Donelson

SALT Select Developments - April 2022

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

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

Arkansas's Answer to the SALT Cap for Business Owners: The Arkansas Pass-Through Entity Tax Act

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

The Tax Cuts and Jobs Act of 2017 (The “TCJA”) imposes a $10,000 cap on the amount an individual may deduct for federal tax purposes for the payment of state and local income, property and sales taxes (referred to as “SALT”)....more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Miles & Stockbridge P.C.

And Then There Were Some: Maryland, Virginia, and DC’s Stance on Pass-Through SALT Deduction Workarounds

Miles & Stockbridge P.C. on

In late 2020, the IRS issued a notice confirming imminent proposed regulations that would allow certain tax strategies to avoid the individual $10,000 state and local tax (“SALT”) deduction limitation of the Tax Cuts and Jobs...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Bradley Arant Boult Cummings LLP on

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

Foster Garvey PC on

Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Billionaires Tax

Cadwalader, Wickersham & Taft LLP on

On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

ArentFox Schiff on

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Bradley Arant Boult Cummings LLP on

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

McDermott Will & Emery

Illinois Enacts Pass-Through Entity Tax to Help Partners and S Corporation Shareholders Avoid the $10,000 SALT Cap

McDermott Will & Emery on

Illinois enacted a pass-through entity tax (PTE Tax) that may be elected by partnerships and S corporations to permit a federal deduction of state income taxes that otherwise are limited to $10,000 per year from 2018 to 2025...more

Burr & Forman

The Death of S Corporations?

Burr & Forman on

Corporations, limited liability companies, and certain other business entities can make an election with the Internal Revenue Service to be taxed under Subchapter S of the Internal Revenue Code.  If such an election is made,...more

Smith Anderson

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

Smith Anderson on

With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

Bradley Arant Boult Cummings LLP

The MTC Undertakes an Ambitious Study of Partnership Taxation

Bradley Arant Boult Cummings LLP on

On April 27, 2021, the Multistate Tax Commission (MTC) Uniformity Committee voted to accept its Standing Subcommittee’s recommendation to create a work group to study several key issues relating to multistate taxation of...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Foodman CPAs & Advisors

IRS Is On A Mission Is To Reduce The Tax Gap

Foodman CPAs & Advisors on

The difference between the amount of tax owed by Taxpayers for a given year and the amount that is actually paid timely for that same year is known as the “Gross Tax Gap”. The IRS looks at this number as an estimate of the...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

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