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Pass-Through Entities Income Taxes State Taxes

Baker Donelson

SALT Select Developments - May 2024

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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

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

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

Bradley Arant Boult Cummings LLP

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

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

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

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

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

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

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

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

Opportune LLP

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

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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

Greenberg Glusker LLP

California Provides Path to Deduct State Income Tax for Calculating Federal Tax [UPDATED]

Greenberg Glusker LLP on

In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Kramer Levin Naftalis & Frankel LLP

M&A Structuring Opportunities Utilizing State Level Pass-Through Entity Tax Regimes

State-level pass-through entity tax (PTET) regimes offer structuring opportunities in M&A transactions involving S corporation targets. PTET regimes have been adopted by a growing number of states as a workaround to the...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

Rivkin Radler LLP on

Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Miles & Stockbridge P.C.

And Then There Were Some: Maryland, Virginia, and DC’s Stance on Pass-Through SALT Deduction Workarounds

In late 2020, the IRS issued a notice confirming imminent proposed regulations that would allow certain tax strategies to avoid the individual $10,000 state and local tax (“SALT”) deduction limitation of the Tax Cuts and Jobs...more

BakerHostetler

[Podcast] Phasing Out Corporate Income Taxes - North Carolina Edition

BakerHostetler on

Matt Hunsaker discusses recent North Carolina tax legislation, including phase-out/phase-down of corporate and individual income tax rates, an elective passthrough entity SALT cap workaround, and simplification of the...more

Smith Anderson

Finance Provisions of the 2021 Budget Bill

Smith Anderson on

On November 15, 2021, after months of negotiations and four and a half months into the new fiscal year, the North Carolina General Assembly released Senate Bill 105, its proposed budget bill (the "Bill"). Both Chambers...more

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

Foster Garvey PC on

Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

ArentFox Schiff on

While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

BakerHostetler

[Podcast] Bears & California's SALT Cap Workaround

BakerHostetler on

Matt Hunsaker gives an overview of the recently enacted passthrough workaround to the $10,000 state and local tax deduction cap....more

Blank Rome LLP

New York State Tax Department Issues Guidance on Pass-Through Entity Tax

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The New York State Department of Taxation and Finance has issued guidance on the recently enacted New York Pass-Through Entity Tax. Technical Memorandum, “Pass-Through Entity Tax,” TSB-M-21(1)C, (1)I (N.Y.S. Dep’t of Taxation...more

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