News & Analysis as of

Pass-Through Entities Income Taxes

Tax Law’s Impact on Real Estate Industry

by Moskowitz LLP on

This GlobeSt.com article features an interview with Moskowitz Attorney Steve Moskowitz. The new tax law promises to have a significant impact on owners, investors and the real estate industry as a whole. In this exclusive,...more

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

by Dechert LLP on

President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax

by Fenwick & West LLP on

This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more

Deducting Attorneys’ Fees Under the Tax Cuts and Jobs Act of 2017

The Tax Cuts and Jobs Act of 2017 (the “2017 Act”) purports to bring broadly lower tax rates to most U.S. individuals and companies; however, it does so at the expense of clear tax policy objectives in many areas. That lack...more

Alabama Legislature Passes Bill to Address Calculation of Credit for Taxes Paid to Other States - State & Local Tax Alert: Alabama...

Gov. Kay Ivey signed House Bill 384, into law last Wednesday, March 28, ending a debate that has lasted for almost a decade over the scope of the individual income tax credit for certain taxes paid to other states. ...more

The Tax Laws Changed. Should Your Business and Estate Plans Change Too?

by Thompson Coburn LLP on

On January 1, 2018, the most significant changes to the U.S. tax code in 30 years took effect. While the permanency of these changes varies, they are all currently scheduled to continue until at least 2026, which is long...more

FERC Addresses Effects of Tax Cuts on Jurisdictional Rates and Disallows Income Tax Component in MLP-Owned Partnership Pipeline...

On March 15, 2018, the Federal Energy Regulatory Commission (“FERC”) issued an order on remand disallowing an income tax component in cost-of-service rates charged by an interstate oil pipeline owned by a master limited...more

2017 Tax Act: Choice of Entity

by White and Williams LLP on

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

New 20% Deduction For Pass-Through Income

The new Tax Cuts and Jobs Act provides a 20% non-itemized deduction for “qualified business income” (business income received by an owner of a pass-through entity) beginning in 2018. Such pass-through income - reduced by...more

Time to Reconsider Your Choice of Entity?

One of the most publicized changes made by last year’s Tax Cut and Jobs Act was a reduction in income tax rates for corporations and individuals. The maximum corporate tax rate has been permanently reduced from 35% to 21%,...more

Employment & Benefits News and Developments

by Sullivan & Worcester on

NEW TAX LAW MAKES CHANGES TO COMMUTING BENEFITS - ...The Tax Cuts and Jobs Act of 2017 (“TCJA”) generally eliminates employer deductions for commuter transportation and parking fringe benefits. This includes deductions...more

Tax Reform: Impact on Businesses and Individuals

The 2017 Tax Act - Signed into law on December 22, 2017 - Provisions apply NOW – to taxable years beginning after December 31, 2017 - Corporate and International Changes are “permanent;” almost all individual changes...more

2017 New Tax Law: Pass Through Provisions

by Blank Rome LLP on

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

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

by McNair Law Firm, P.A. 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

When Is A Shareholder’s “Loan” To An S Corporation Really A Loan?

by Farrell Fritz, P.C. on

Passing Through Losses- There is a problem that will sometimes plague the shareholders of an S corp that is going through challenging financial times. Whether because of a downturn in the general economy or in its...more

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

New Carried Interest Rules of Interest to Real Estate Developers and Asset Managers

by McNair Law Firm, P.A. on

Prior to the passage of the Tax Cuts and Jobs Act (the “Act”), one of the more controversial and hotly-debated tax benefits was the so-called “carried interest,” which allowed certain fund managers and venture capital firms...more

Federal Tax Reform and Minnesota Tax Policy: A Preliminary Guide to Conformity

by Faegre Baker Daniels on

Since the enactment of the Tax Cuts and Jobs Act (TCJA), Minnesota’s Department of Revenue (DOR) has been analyzing what the TCJA will mean for Minnesota. The TCJA marks the most significant changes to the Internal Revenue...more

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

by Garvey Schubert Barer on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

FERC and the Tax Cuts and Jobs Act of 2017 – Natural Gas Pipelines

The Federal Energy Regulatory Commission (FERC) Staff has initiated inquiries involving numerous interstate natural gas pipelines, seeking information on the impact of the Tax Cuts and Jobs Act of 2017 (Tax Act) on those...more

Impact of Tax reform on Commercial Real Estate

by K&L Gates LLP on

MOST SWEEPING TAX REFORM SINCE 1986 - Tax Cuts and Jobs Act signed December 22, 2017 - Generally effective for taxable years beginning after December 31, 2017 - Comprehensive tax reform affecting virtually all...more

5 Helpful Things to Know About the New Limitation on Claiming Losses

Last month, President Trump signed into law the much publicized Tax Cut and Jobs Act. In part of our ongoing series discussing the changes made by the Act, the following answers five common questions regarding the new...more

Private Equity Fund Taxation Post-Tax Reform: What Really Changed?

Congress has passed the tax reform bill, known as the “Tax Cuts and Jobs Act” (the “Act”), and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law, many of which will...more

Decoding the Tax Cuts and Jobs Act – Part IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

by Garvey Schubert Barer on

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

Real Estate Aspects of Tax Reform

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax laws will have a significant impact upon...more

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