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Hinckley Allen

Understanding 2024 Estate, Gift, and Generation-Skipping Transfer Tax Exemptions

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Each year, certain estate, gift, and generation-skipping transfer (“GST”) tax figures are subject to inflation adjustments that go in effect on January 1. Below are the current adjustments for 2024....more

Cozen O'Connor

Pennsylvania Amends Tax Treatment of Grantor Trusts As of January 1, 2025

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Starting January 1, 2025, the individual who is the grantor of a trust that qualifies as a grantor trust under Sections 671 through 679 of the Internal Revenue Code will himself or herself be subject to Pennsylvania Personal...more

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

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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

WilmerHale

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

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In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...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

Freeman Law

Texas Tax Roundup | August 2022

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Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more

Venable LLP

Seller Beware - Court Rules That California Can Tax Gain from the Sale of Goodwill

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A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more

Bradley Arant Boult Cummings LLP

Important Tax Legislation to Watch in the 2022 Alabama Regular Session

Because 2022 is an election year, the start date for the Alabama Legislature’s regular session comes early: Tuesday, January 11. As we do annually, here are some unofficial prognostications on the major items of tax...more

Smith Anderson

Finance Provisions of the 2021 Budget Bill

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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

Bowditch & Dewey

Massachusetts Taxpayers Find More Complexity in Differences Between Massachusetts and Federal Tax Law

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It seems every year there are changes to the Internal Revenue Code (IRC). It is a challenge, even for tax pros, to keep up with the ever-changing tax code. Massachusetts taxpayers also have an added challenge in keeping up...more

ArentFox Schiff

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

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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

Schwabe, Williamson & Wyatt PC

Enactment of SB 164 and Changes to Oregon's Corporate Activity Tax

Although Oregon’s 2021 legislative session turned out to be relatively quiet from a tax perspective, we did experience some changes to Oregon’s Corporate Activity Tax (“CAT”). Those changes were primarily in the form of SB...more

Holland & Hart LLP

The Disappearing Deduction for Colorado State Income Tax Purposes

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On June 23, 2021, Governor Polis signed Colorado House Bill 21-1311 into law. The Bill makes significant changes to a number of Colorado state income tax laws. One change of note is an amendment to C.R.S. § 39-22-104. The...more

BakerHostetler

[Podcast] How Will States Tax Forgiven PPP Loans?

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The CARES Act created the Paycheck Protection Program. The PPP allowed businesses to secure forgivable SBA loans. Federal taxation of forgiven loans and related expenses are quite favorable - will states follow suit? Matt...more

Dentons

Miscellaneous Tax Changes in HF2641

Dentons on

In the final day of the 2020 session, the Iowa legislature passed a bill that enacted several changes to Iowa tax laws. This post addresses several miscellaneous changes made to the tax laws that are effective immediately....more

Foster Garvey PC

The Oregon Department of Revenue Held Its CAT Call as Scheduled – The Business and Tax Community Were Represented

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As we reported last week, the Oregon Department of Revenue (“DOR”) scheduled a public hearing on June 23, 2020 to discuss the second set of temporary administrative rules relative to the Oregon Corporate Activity Tax (the...more

Farrell Fritz, P.C.

States’ Rights, State Taxation, And . . . New York “S” Elections?

Farrell Fritz, P.C. on

How Did We Get Here? On September 9, 1776, Congress officially adopted “United States” of America as the name of our then-newly-born nation. The former British colonies had previously referred to themselves as the “United...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

Nutter McClennen & Fish LLP

Massachusetts Senate Does Not Decouple From IRC 163(j)

We reported on a provision in the supplemental budget passed by the Massachusetts House of Representatives. That provision decoupled the Massachusetts tax code from Internal Revenue Code Section 163(j). The governor has also...more

Nutter McClennen & Fish LLP

Massachusetts May Refuse to Adopt Federal Interest Expense Limits

The Massachusetts House of Representatives overwhelmingly voted in favor of a bill to decouple the Massachusetts tax code from a significant federal interest deduction limitation. The federal limitation is contained in...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

Foster Garvey PC

Now You See It – Now You Don’t. Like Magic, the City of Portland Disallows Depreciation Deductions Otherwise Allowable as a Result...

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Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more

Proskauer Rose LLP

Wealth Management Update - July 2019

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Supreme Court Ruling in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, 588 U.S. [TBD] and its Relevance to Income Taxation of Accumulated Income in California Trusts - The Supreme Court...more

Foster Garvey PC

Oregon’s New Corporate Activity Tax

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We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation. On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more

McDermott Will & Emery

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

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On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

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