News & Analysis as of

Pass-Through Entities Tax Reform Tax Cuts and Jobs Act

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

Whiteford on

In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...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

Sullivan & Worcester

SALT Cap Workaround and Other Tax Provisions in the Pending Massachusetts FY22 Budget

Sullivan & Worcester on

On Friday, July 9, the Massachusetts Legislature voted in favor of the Conference Committee’s revised fiscal year 2022 (FY22) budget bill, House No. 4002[1] (budget bill). The Governor has until Monday, July 19 to either...more

Bradley Arant Boult Cummings LLP

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Burr & Forman

South Carolina May Join Other States to Provide State and Local Tax Cap Workaround

Burr & Forman on

The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a $10,000 cap on the federal deduction for state and local taxes for tax years 2018-2025.  While corporations are not subject to the cap, business owners who pay state and...more

Bradley Arant Boult Cummings LLP

TCJA Reform/CARES Act Bill Introduced in both House and Senate

On January 28, HB 170 and its Senate counterpart, SB 98, were prefiled with the Alabama Legislature and designated as three separate acts: (i) The Alabama Taxpayer Stimulus Freedom Act of 2021, (ii) The Alabama Business Tax...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

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

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...

Seyfarth Shaw LLP on

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

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

Holland & Knight LLP on

The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

McGuireWoods LLP

Advanced Issues for DPM & PPM Transactions and Platforms: Business Tax Issues in Light of Tax Reform – Key Takeaways

McGuireWoods LLP on

The next in our series of posts sharing key takeaways from panels at the Healthcare & Life Sciences Private Equity and Lending Conference discusses investing in designated primary market makers and private placement...more

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...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

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...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

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

McGuireWoods LLP

IRS Proposes Regulations on New Section 199A Passthrough Deduction

McGuireWoods LLP on

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

BakerHostetler on

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

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Proskauer - Tax Talks

State Tax Law Updates

Proskauer - Tax Talks on

A number of states have recently proposed or passed new laws related to state-level taxation, some of which are taxpayer-friendly and some of which are expected to impose additional tax burdens on taxpayers. They vary in...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more

Verrill

Connecticut Reacts to Federal Tax Law Reform Changes

Verrill on

The sweeping changes created by the federal Tax Cuts and Jobs Act (“TCJA”) has resulted in some states enacting their own legislation in response to the federal tax reform. On May 31, 2018, Connecticut signed into law a bill...more

Pullman & Comley, LLC

Are Connecticut Income Taxes Now Tax Deductible For The Owners Of Pass-Through Entities?

Pullman & Comley, LLC on

June 5, 2018 The Tax Cuts and Jobs Act, which was passed by Congress last year, imposed a $10,000 limit on state and local tax (“SALT”) deductions. ...more

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