News & Analysis as of

Limited Liability Company (LLC) S-Corporation Tax Deductions

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

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

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

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

Kerr Russell

Michigan Enacts SALT Cap Workaround For Pass-Through Entities

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On December 20, 2021, Governor Gretchen Whitmer signed legislation (H.B. 5376) allowing owners of S corporations and partnerships (including limited liability companies taxed as partnerships) to pay their state and local...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

Rivkin Radler LLP on

Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Farrell Fritz, P.C.

Can A Partnership’s Payment To A Partner For Services Not Be Treated As Such For Purposes Of Sec. 199A?

Farrell Fritz, P.C. on

Memory Lane- You may recall how clear it became, as the bill that would become the Tax Cuts and Jobs Act (“TCJA”) moved through Congress in late 2017, that C corporations were about to realize a number of tax benefits,...more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

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The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

White and Williams LLP

IRS to Allow “Workaround” to Deduction Limits for State and Local Income Taxes

White and Williams LLP on

The Tax Cuts and Jobs Act (2017 Tax Act) limited the deduction of state and local taxes to $10,000 for individuals. Several states, including Connecticut, New Jersey and Maryland, have passed legislation that imposed income...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Pullman & Comley, LLC

Waiver Of Penalties And Interest In Connection With 2018 Pass-Through Entity Tax

Pullman & Comley, LLC on

In the Spring of 2018, the Connecticut Legislature adopted a Pass-Through Entity Tax (the “PE Tax”), which imposes a 6.99% tax on pass-through entities (partnerships, limited liability companies and S-corporations). The PE...more

Burr & Forman

Section 199A – The Decision to Aggregate

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Does It Apply To Rental Real Estate Activities?

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Rosenberg Martin Greenberg LLP

Loughman Case Illustrates Potential Impact of Entity Choice on Income Tax Liability for Cannabusinesses

Recognition of Internal Revenue Code (“I.R.C.”) § 280E and its potential to limit deductions can have a material impact on the ongoing operation of a cannabusiness. While operational concerns require attention, improper tax...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Employee Leasing May Help

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Baker Donelson

Qualified Business Income Deduction Guidance Package Released

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Despite the ongoing partial government shutdown, the IRS issued four sets of guidance (the Guidance Package) on January 18 related to the new deduction for owners of pass-through entities of up to 20 percent of their...more

Blank Rome LLP

2019 Estate and Tax Planning Newsletter

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Blank Rome’s annual estate and tax planning newsletter addresses estate planning concepts and techniques that should be considered in 2019 by our clients and friends. 1. Transfer Taxes. The major changes made in 2010 in...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Burr & Forman

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

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Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

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A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Alston & Bird

Certain Banks Qualify for the 20% Pass-Through Deduction

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Our Federal Tax Group highlights Section 199A and the IRS’s new proposed regulations that allow pass-through businesses to deduct up to 20% of their qualified business income....more

Burr & Forman

IRS Issues New Proposed Regulations on Section 199A 20% Deduction for Pass-Through Businesses

Burr & Forman on

The Internal Revenue Service yesterday issued its much-anticipated Proposed Regulations on the new Section 199A 20% deduction for owners of pass-through business entities. This important deduction was created under the 2017...more

Foster Garvey PC

Newly Proposed IRS Regulations Put a Monkey Wrench in Plans by Service Businesses Seeking IRC § 199A Deduction

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The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

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 IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

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BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...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

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