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Pass-Through Entities Business Income

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Williams Mullen

Tax Planning Opportunity for Owners of Pass-Through Entities: Virginia Enacts Workaround to $10,000 Federal Income Tax Limitation...

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Virginia recently enacted legislation that provides an opportunity for the owners of a qualified pass-through entity (PTE) to reduce their federal income tax liability if the PTE makes an election to pay Virginia taxes at the...more

Bradley Arant Boult Cummings LLP

The MTC Undertakes an Ambitious Study of Partnership Taxation

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

New York Budget Deal Includes SALT Cap Workaround

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The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Board of Tax Appeals denies Taxpayers Business Income Deduction due to Improperly Introduced Evidence

Retaining experienced counsel with knowledge of not only proper procedure but how to present a case is critical to prevailing at the Board of Tax Appeals (BTA). Recently, the BTA denied the taxpayer’s claim for a business...more

Seyfarth Shaw LLP

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

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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

Farrell Fritz, P.C.

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

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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

BakerHostetler

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

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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

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Initial Takeaways on Clarification of Definition of "Specified Service Trade or Business"

Since the passage of the Tax Cuts and Jobs Act, business owners and tax practitioners alike have focused on the potential effect of Section 199A. Though it has been clear for some time that the 20% deduction afforded to...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

Burr & Forman

IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed...

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On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more

Farrell Fritz, P.C.

Trusts And The Section 199A Deduction

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If there was one part of the Tax Cuts and Jobs Act (“TCJA”) that estate planners were especially pleased to see, it was the increase in the basic exclusion amount from $5.49 million, in 2017, to $11.18 million for gifts made,...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

Nelson Mullins Riley & Scarborough LLP

Proposed Regulations Provide Guidance on 20% Deduction for Qualified Business Income

The Department of Treasury issued in August proposed regulations (REG-107892-18) (the “Proposed Regulations”) under Section 199A of the Internal Revenue Code, providing individual taxpayers with interests in certain...more

Foodman CPAs & Advisors

Is calculating the 20 percent deduction for pass-through businesses simple?

Section 199A of the Internal Revenue Code provides Individual Taxpayers a deduction for the Qualified Business Income (QBI) of a qualified trade or business operated directly or through a pass-through entity....more

Dentons

Overview of Limitations to QBI Deductions Under IRC Section 199A

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Under the newly enacted Internal Revenue Code Section 199A, owners of pass-through entities, such as LLCs, partnerships, trusts, sole proprietorships, and S corporations, may deduct up to 20% of their qualified business...more

Farrell Fritz, P.C.

The Proposed Sec. 199A Regs Are Still Here! Part Four

Farrell Fritz, P.C. on

This is the fourth[i] and final in a series of posts reviewing the recently proposed regulations (“PR”) under Sec. 199A of the Code. ...more

Akerman LLP

U.S. Issues Proposed Tax Regulations For Section 199A Qualified Business Income Deduction

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On August 8, 2018, the Treasury Department and Internal Revenue Service released Proposed Regulations clarifying issues that arise under Section 199A of the Internal Revenue Code of 1986, as amended (the “Code”). This...more

Farrell Fritz, P.C.

The Proposed Sec. 199A Regs Are Here! Part Three

Farrell Fritz, P.C. on

This is the third in a series of posts reviewing the recently proposed regulations (“PR”) under Sec. 199A of the Code. So far, we’ve considered the elements of a “qualified trade or business” under Section 199A...more

Burr & Forman

New IRS §199A Proposed Regulations Provide Guidance On “Qualified Business Income”: What Income is “In” and What Income is “Out”...

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The IRS has issued Proposed Regulations now under the new Section 199A 20% profit deduction for pass-through entities. The Proposed Regulations provide important guidance on the definition of “Qualified Business Income” –...more

McGuireWoods LLP

IRS Proposes Regulations on New Section 199A Passthrough Deduction

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On August 8, the Internal Revenue Service (IRS) and the Department of the Treasury released proposed regulations on new section 199A, the 20 percent deduction for qualified business income, added to the Internal Revenue Code...more

Burr & Forman

New IRS Proposed 199A Regulations Provide Guidance on 20% Profit Pass-Through Deduction

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On August 8th, the IRS released its much-awaited Proposed Regulations on the new Section 199A 20% profit deduction for pass-through businesses. The new deduction applies to essentially all types of businesses other than C...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

Baker Donelson

The Qualified Business Income Deduction: Proposed Regulations Shed Light on Several Key Issues

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The 2017 tax reform bill created a new deduction for owners of pass-through entities (partnerships, LLCs taxed as partnerships, S corporations, and sole proprietorships) of up to 20 percent of their "qualified business...more

Burr & Forman

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

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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

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