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Qualified Business Income Internal Revenue Service

Roetzel & Andress

Now That We’ve Seen the Eclipse, It’s Time To Plan for the TCJA Sunset

Roetzel & Andress on

As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposal on Domestic Businesses

Bowditch & Dewey on

On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Farrell Fritz, P.C.

Can A Partnership’s Payment To A Partner For Services Not Be Treated As Such For Purposes Of Sec. 199A?

Farrell Fritz, P.C. on

Memory Lane- You may recall how clear it became, as the bill that would become the Tax Cuts and Jobs Act (“TCJA”) moved through Congress in late 2017, that C corporations were about to realize a number of tax benefits,...more

Jones Day

IRS Increases Enforcement Efforts on Large Businesses

Jones Day on

The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act. The IRS Large Business and International ("LB&I")...more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Baker Donelson

Rental Real Estate Enterprises – Section 199A Safe Harbor for Treatment as Trade or Business

Baker Donelson on

The IRS recently (September 2019) published Rev. Proc. 2019-38, finalizing the proposed safe harbor requirements under which a rental real estate enterprise (RREE) will qualify as a trade or business for purposes of Internal...more

ArentFox Schiff

IRS Provides Safe Harbor for Rental Real Estate Owner Tax Deduction

ArentFox Schiff on

On September 24, the IRS issued Revenue Procedure 2019-38, clarifying rental real estate owners’ eligibility for the highly anticipated tax break under section 199A of the Internal Revenue Code. Section 199A Deduction...more

Lowndes

IRS Finalizes Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business.  Whether rental activity rises to the level of a trade or business can often be a...more

Burr & Forman

Section 199A – The Decision to Aggregate

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

McDermott Will & Emery

Weekly IRS Roundup May 6 – 10, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more

Lowndes

Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. Many senior living communities hold their real property in a separate entity,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation - April 2019

IN THIS ISSUE - Tax Tidbit - Legislative Lowdown - - Congress’s Kumbaya Moment - Biodiesel Tax Credit - Moore Trouble for Fed Pick - And the Results Are In 1111 Constitution Avenue...more

Buchalter

Comments on Proposed 199A Regs Regarding Qualified REIT Dividends Due Soon

Buchalter on

Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more

Burns & Levinson LLP

Alpenglow at It Again

Burns & Levinson LLP on

As discussed in more detail in my prior post, Alpenglow Botanicals (“Alpenglow”) is a state licensed Marijuana dispensary based in Colorado. Alpenglow was audited for several tax years and the IRS made adjustments, denying...more

Snell & Wilmer

The Pass-Through Income Deduction for Charitable Remainder Trusts

Snell & Wilmer on

On January 18, 2019, the Internal Revenue Service (IRS) issued final regulations implementing the new pass-through income deduction for qualified business income (QBI) received from pass-through entities (such as sole...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

Proskauer - Tax Talks

“Passthrough Deduction” Regulations Finalized

Proskauer - Tax Talks on

On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more

Rosenberg Martin Greenberg LLP

Are Owners of Cannabusinesses Eligible for the Qualified Business Income Deduction Under Section 199A?

Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more

Latham & Watkins LLP

Tax Reform: Final Regulations Clarify Framework for Determining Pass-Through Income Deduction

Latham & Watkins LLP on

Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Employee Leasing May Help

Burr & Forman on

Under the 2017 Tax Cuts and Jobs Act, Congress enacted a new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Williams Mullen

The Proposed Real Estate Safe Harbor for the Qualified Business Income Deduction

Williams Mullen on

On January 18th, the U.S. Department of Treasury and the Internal Revenue Service issued a package of guidance relating to the 20-percent qualified business income deduction for non-corporate taxpayers under Section 199A of...more

Lowndes

IRS Announces New Real Estate Safe Harbor for 20% QBI Deduction

Lowndes on

Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. ...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings. Hopefully, their...more

McDermott Will & Emery

Weekly IRS Roundup January 28 – February 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 28 – February 1, 2019. January 28, 2019: The IRS issued Revenue Ruling 2019-04,...more

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