News & Analysis as of

Pass-Through Entities Tax Deductions

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

Allen Barron, Inc.

California and IRS Extended Income Tax Deadlines are Rapidly Approaching

Allen Barron, Inc. on

The California and IRS extended income tax deadlines are rapidly approaching as we near the deadline in mid-October.  In the first few months of 2023 California and the IRS extended income tax deadlines and associated...more

Woods Rogers

Following the Government’s Playbook: Tax Incentives for CRE Investments 

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Investing in commercial real estate can offer various tax incentives that can help investors reduce their tax liability and enhance the overall profitability of their investments. Below is a non-exhaustive summary of key tax...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

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

Polsinelli on

Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more

Fox Rothschild LLP

Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases

Fox Rothschild LLP on

On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by...more

Roetzel & Andress

End of Year Tax Planning: Tips for Healthcare Professionals and Practices

Roetzel & Andress on

Ericka Adler, Roetzel shareholder and Health Law Practice Group Leader, is joined by fellow shareholder Donna Hartl on the #HealthLawHotSpot this week, to discuss what healthcare professionals and their practices should be...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

Buckingham, Doolittle & Burroughs, LLC

Ohio Income Tax – Ohio Jumps on Trend to Codify SALT Deduction Cap Workaround

Last year, a post explained that investors in Ohio pass-through entities (PTEs) may be able to avoid the $10,000 state and local tax (SALT) deduction cap using Ohio’s composite return election. Now a little over a year later,...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

Greenberg Glusker LLP

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

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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

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

Freeman Law

Syndicated Conservation Easements (and Other Tax Schemes) Beware

Freeman Law on

Syndicated Conservation Easements - In an IRS news release of January 17, 2022, the IRS’s Office of Chief Counsel announced that plans to hire up to 200 additional attorneys “to help the agency combat syndicated...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

Kerr Russell

Michigan Enacts SALT Cap Workaround For Pass-Through Entities

Kerr Russell on

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

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

Nutter McClennen & Fish LLP

Overriding the Governor, Massachusetts Legislature Gives Pass-Through Entity Owners a Workaround to Federal SALT Deduction Cap

The Massachusetts legislature, overriding Governor Baker’s prior veto, has voted to enact a new elective pass-through entity (“PTE”) tax designed as a way for PTE owners to get out from under the $10,000 cap ($5,000 for...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

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

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 that limits the deductibility of...more

McDermott Will & Emery

Illinois Enacts Pass-Through Entity Tax to Help Partners and S Corporation Shareholders Avoid the $10,000 SALT Cap

Illinois enacted a pass-through entity tax (PTE Tax) that may be elected by partnerships and S corporations to permit a federal deduction of state income taxes that otherwise are limited to $10,000 per year from 2018 to 2025...more

Blank Rome LLP

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

Blank Rome LLP on

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

Kilpatrick

4 Key Takeaways | Mid-Year Tax Update

Kilpatrick on

On June 22, 2021, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the...more

Bowditch & Dewey

Massachusetts Legislature Passes Legislation Enacting Work Around to Federal $10,000 SALT Deduction Limitation, but Governor Baker...

Bowditch & Dewey on

On July 16, 2021, Governor Baker approved a $47.6 billion fiscal 2022 budget, but sent back a provision the Massachusetts Legislature passed creating a workaround for the federal cap on the state and local tax deduction. ...more

Cadwalader, Wickersham & Taft LLP

Wyden Proposes Expansion of Pass-Through Deduction

On July 20, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) proposed legislation to modify the 20% deduction allowed to investors in certain pass-through businesses under Section 199A....more

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