News & Analysis as of

S-Corporation Internal Revenue Code (IRC) Limited Liability Company (LLC)

Frost Brown Todd

To Be Clear…LLCs Can Issue Qualified Small Business Stock (QSBS)

Frost Brown Todd on

Since the finalization of the IRS’s “check-the-box” entity-classification regulations nearly 30 years ago, a state law LLC can elect to be taxed an association taxable as a corporation. During the past month, we have heard...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

Hinckley Allen on

Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The ManyTraps That Exist For The Unwary: Part I – The...

Foster Garvey PC on

In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary. This year, in a multi-part article, I intend to take our blog...more

Vicente LLP

Forming Psychedelic Companies: 10 Lessons from the Cannabis Industry

Vicente LLP on

A new industry is emerging in the United States, and entrepreneurs in the psychedelics space must make critical decisions at the onset of new ventures regarding how to set up and structure their new businesses. While there is...more

Williams Mullen

ESOP Essentials: Can My Company Offer An ESOP? Selected Tax Guidance on Choice of Entity, Business Structure and ESOPs

Williams Mullen on

An employee stock ownership plan (ESOP) is a type of tax-qualified retirement plan. ESOPs are designed to invest primarily in qualifying employer securities, as defined in applicable tax rules....more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

Cole Schotz on

The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

Episode #22 The Accidental Entrepreneur - The Optimal Corporate Set Up discusses the virtues and financial powers of creating your own business as a vehicle for ensuring your current and future financial stability. Consider...more

Gerald Nowotny - Law Office of Gerald R....

The Accidental Entrepreneur - Part II The Optimal Corporate Set Up

In April 2016, I wrote Part One of this series. You can read this article on JD Supra. Part One focused on the hobby loss tax rules. Four years later I am writing part two. Did I forget that I had written part one? Perhaps!...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Mitchell, Williams, Selig, Gates & Woodyard,...

S Election Terminated as a Result of Form Operating Agreement Language

A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more

Rosenberg Martin Greenberg LLP

Loughman Case Illustrates Potential Impact of Entity Choice on Income Tax Liability for Cannabusinesses

Recognition of Internal Revenue Code (“I.R.C.”) § 280E and its potential to limit deductions can have a material impact on the ongoing operation of a cannabusiness. While operational concerns require attention, improper tax...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Burr & Forman

IRS Issues New Proposed Regulations on Section 199A 20% Deduction for Pass-Through Businesses

Burr & Forman on

The Internal Revenue Service yesterday issued its much-anticipated Proposed Regulations on the new Section 199A 20% deduction for owners of pass-through business entities. This important deduction was created under the 2017...more

Foster Garvey PC

Newly Proposed IRS Regulations Put a Monkey Wrench in Plans by Service Businesses Seeking IRC § 199A Deduction

Foster Garvey PC on

The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more

Burr & Forman

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

Burr & Forman 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

Foster Garvey PC

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

Foster Garvey PC 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

Burr & Forman

New Internal Revenue Code Section 199A: The 20% Deduction for “Pass-Thru” Businesses

Burr & Forman on

Aside from corporate tax reductions, one of the most important aspects of the new Tax Cuts and Jobs Act beginning this year is the new 20% deduction for “pass-thru” businesses – i.e. businesses that are not corporations. With...more

Baker Donelson

Spotlight On Alabama: A Busy Tax Year in Review

Baker Donelson on

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

Gerald Nowotny - Law Office of Gerald R....

State of the Union - Part 2: Retirement with a Capital R

Overview - Since my last article, I have received some hate mail. Well, not quite literally unless I count the note from Mrs. Nowotny asking me why I forgot half of the items on the grocery list. A number of readers...more

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