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Income Taxes › Pass-Through Entities

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 -
Baker Donelson

SALT Select Developments - May 2024

Baker Donelson on

State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Miles & Stockbridge P.C.

Md. Comptroller Offers Relief for Missed 2023 PTE Elections

Miles & Stockbridge P.C. on

Maryland Comptroller Brooke Lierman issued a letter Feb. 28 to address the challenges and concerns of tax practitioners regarding the policy and procedural changes to pass-through entity (PTE) filings and payments. Most...more

Williams Mullen

2023 Developments in Virginia Taxation

Williams Mullen on

A Summary Review of Tax Legislation, Court Decisions, Opinions of the Attorney General and Published Rulings of the Tax Commissioner Published from January 1, 2023 through November 10, 2023....more

Gray Reed

Phantom Income: The Spooky Side of Taxation

Gray Reed on

There’s a hidden tax horror behind pass-through entities, cancellation of debt, and even prizes, winning, and awards: “phantom income.” It even sounds scary, right? And when it comes to one’s tax liability, it can be...more

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

Venable LLP on

Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

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Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

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

Skadden, Arps, Slate, Meagher & Flom LLP on

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

Miles & Stockbridge P.C.

Maryland Updates Pass-Through Entity Election Requirements

Miles & Stockbridge P.C. on

The Maryland Comptroller’s Office issued a Tax Alert on April 11, 2023 addressing policy and procedural changes to pass-through entity (PTE) filings and payments. For tax years beginning after Dec. 31, 2022, PTEs are required...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

Williams Mullen

Virginia Dept of Tax Issues Clarifying Guidance for Recent Changes to Pass-Through Entity Tax

Williams Mullen on

The General Assembly enacted legislation (H.B. 1456 and S.B. 1476) during its 2023 Regular Session that removed some of the barriers for qualifying for Virginia’s Pass-Through Entity Tax (PTET) election and altered how PTET...more

Eversheds Sutherland (US) LLP

Georgia’s 2023 legislative session ends with significant tax legislation

Eversheds Sutherland (US) LLP on

During the 2023 legislative session, the Georgia General Assembly passed significant tax legislation including decoupling from IRC § 174, imposing sales tax on certain digital goods, and revising eligibility for the...more

Williams Mullen

Virginia’s General Assembly Enacts New Tax Legislation in 2023 (Chart Included)

Williams Mullen on

The table below summarizes the tax legislation enacted by the General Assembly during its 2023 Regular Session and approved by Gov. Youngkin that will become law on or before July 1, 2023. Please note that any legislation...more

Williams Mullen

Increased Flexibility for Pass-Through Entity Tax Election Passes Through General Assembly

Williams Mullen on

During its 2023 Session, the Virginia General Assembly passed legislation, H.B. 1456 and S.B. 1476, that removes some of the barriers for participating in Virginia’s elective Pass-Through Entity Tax (PTET)....more

Sands Anderson PC

Update on Potential Tax Savings Opportunity: Virginia’s Pass-through Entity Tax and SALT Cap Deduction Workaround

Sands Anderson PC on

For individual owners of pass-through entities, such as partnerships, limited liability companies (“LLCs”), business trusts, and S Corporations, Virginia’s elective Pass-through Entity Tax (“PTET”) offers potential federal...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

J.S. Held

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

J.S. Held on

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

Kohrman Jackson & Krantz LLP

Ohio Enacts New Elective Pass-Through Entity Tax

Kohrman Jackson & Krantz LLP on

Last month, Governor Mike DeWine signed Senate Bill 246, authorizing Ohio pass-through entities (PTE), including S corporations, partnerships and limited liability companies taxed for federal income tax purposes as...more

Cozen O'Connor

Pennsylvania Enacts Record Tax Reform

Cozen O'Connor on

Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, P.L. __. No. 53 (Act 2022-53) (HB 1342) implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions. The bill will:.....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

Opportune LLP

New Mexico Non-Resident Pass-Through Withholding & Composite Return Election

Opportune LLP on

New Mexico recently enacted legislation qualifying pass-through entities to make an annual election to pay an entity-level state tax for taxable years beginning on or after January 1, 2022. Here’s what it means for your oil...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

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