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Pass-Through Entities Business Taxes Tax Reform

Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more

Sands Anderson PC

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

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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

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

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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

Burns & Levinson LLP

VAS Holdings v. Commissioner of Revenue - Taxing Out-of-State Entities on the Sale of a Massachusetts Business

Burns & Levinson LLP on

What Was At Stake - At issue in a recent, significant tax decision of the Supreme Judicial Court (“SJC”) was whether the Massachusetts Commissioner of Revenue could tax an out-of-state shareholder on the gains it derived...more

Proskauer - Tax Talks

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

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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

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

Wyrick Robbins Yates & Ponton LLP

Nine Biden Tax Proposals to Know as We Near Election Day

We’re roughly a month from Election Day, and I think it’s safe to say many Americans have strong opinions about who should be our President for the next four years.  I also think it’s safe to say taxes are not the top...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

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In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...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

Morgan Lewis

NJ Enacts Elective Pass-Through Business Tax to Limit Federal Cap Impact on SALT Deduction

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New Jersey recently enacted the “Pass-Through Business Alternative Income Tax Act,” which allows pass-through businesses with at least one member liable for the New Jersey gross income tax to make an election to pay income...more

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

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As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

Sands Anderson PC

Tax Reform: Section 199A Qualified Business Income Deduction – Safe Harbor for Rental Real Estate Businesses

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The Internal Revenue Code (“IRC”) Section 199A Qualified Business Income Deduction (“QBI Deduction”) generally provides a 20% deduction (or reduction) of a taxpayer’s qualified net business income received from a pass-through...more

Lowndes

The New Deduction For Pass-Through Entities May Apply to Your Tech Business

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Do you have a tech business that you operate as a pass-through entity? If so, Section 199A of the recent tax reform legislation may apply to you or your business. This provision introduces a 20% deduction for qualified...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

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

Akerman LLP on

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

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

BakerHostetler

Opportunities and Limitations: Proposed Pass-Through Deduction Regulations Provide Clarity

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Since new Section 199A was enacted late last year as part of the Tax Cuts and Jobs Act (the TCJA, discussed in Congressional Conferees Approve Long-Awaited Tax Reform), business owners and tax professionals alike have been...more

Baker Donelson

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

Baker Donelson on

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

Verrill

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

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In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

White and Williams LLP

2017 Tax Act: Choice of Entity

We recently prepared an alert on the new 20% qualified business income deduction that was added by the 2017 Tax Act. We have received many questions from our clients and friends about whether, notwithstanding the QBI...more

Blank Rome LLP

2017 New Tax Law: Pass Through Provisions

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On December 20, 2017, Congress passed its comprehensive tax reform bill, the Tax Cuts and Jobs Act (“the Act” or “the Bill”), which was signed into law by President Trump on December 22, 2017. The Bill represents one of the...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

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

The New Deduction for Pass-Through Income (or How Congress Failed at Tax Simplification)

One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs...more

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