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Tax Deductions Taxable Income

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

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Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Rivkin Radler LLP

Transacting With One’s Business – Keep It Arm’s Length

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Don’t Be Unreasonable- Much has been written of late regarding the payment by a business of various personal expenses incurred by its owner or certain key employees. The payment of an owner’s personal expenses appears to...more

McDermott Will & Emery

Finalization of Foreign Tax Credit Rules on Disregarded Payments (Effective Retroactively)

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On January 4, 2022, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) published its third set of final regulations on foreign tax credits (the “Final Regulations”) since the enactment of the Tax Cuts...more

McNees Wallace & Nurick LLC

Pennsylvania Saga re Unconstitutional Dollar-Based Caps on NOL Deduction Continues

There has been a flurry of litigation in recent years involving taxpayer challenges to the constitutionality of Pennsylvania’s statutory cap on net loss carryover (“NOL”) deductions for tax years prior to 2017. First came...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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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

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Ervin Cohen & Jessup LLP

California Assembly Bill No. 80: Tax Treatment of Forgiven Paycheck Protection Program Loans

Our previous articles have summarized the Paycheck Protection Program (“PPP”) created under the Federal CARES Act: CARES Act: Paycheck Protection Program Loans, CARES Act: Loan Applications, CARES Act: Loan Forgiveness...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

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The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

Farrell Fritz, P.C.

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

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Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

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

KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!

Tax Planning for 2020 in 2021, yes you can! Cares Act gives the ability to install a qualified retirement plan. Eliminate 2020 taxation associated with investment income. #taxes #qualifiedretirementplan #financialadvisors...more

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

KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!

Nowotny On Death and Taxes podcast episode 32 Knock Yourself Out - Resuscitating Taxpayer's With Buyer's Remorse; learn how to do tax planning for 2020 in 2021; it's not too late! Eliminate all of your taxation associated...more

Farrell Fritz, P.C.

The “Art” Of Operating Foundations: A Public-Private Venture

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In the Beginning- From the dawn of recorded history, those who have the means have purchased or otherwise financed the work of those whom we call artists – talented individuals capable of producing what we call works of...more

Pierce Atwood LLP

COVID-19: Expenses Paid with PPP Loans Are Not Tax-Deductible

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Late on April 30, 2020 the IRS provided rather unwelcome guidance to Paycheck Protection Program (PPP) loan borrowers and potential borrowers. IRS Notice 2020-32 provides that no deduction will be allowed for otherwise...more

Lowndes

CARES Act Eases Limitation on Deducting Business Interest Expenses

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The 2017 Tax Cuts and Jobs Act introduced a new Section 163(j) limitation on taxpayers deducting business interest expense (our prior discussion of this tax law change can be found). ...more

McDermott Will & Emery

IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

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On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more

Bradley Arant Boult Cummings LLP

New Limitations on Deductions for Interest Payments May Impact Many Family Businesses

The new Tax Cuts and Jobs Act limits the ability of many businesses to deduct interest payments. Under prior law, any interest expense was generally deductible. Now, many businesses are prohibited from deducting any interest...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

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“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Bowditch & Dewey

Year-End Tax Planning Tips

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If Congress is successful in lowering tax rates for at least some taxpayers in 2018, there are several year-end taxing-saving tips to consider prior to December 31st....more

Foodman CPAs & Advisors

Tax Preparation is NOT a Commodity

As we approach this year’s tax filing deadline of April 18th, do you think that you have your Tax Return under control? Before you answer yes, take the time to examine and evaluate who is preparing your taxes. Do they have...more

Troutman Pepper

Tax Proposals to Eliminate Interest Deductions Miss the Mark

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The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

McNees Wallace & Nurick LLC

Pennsylvania’s NOL Cap Litigation Moving Forward

In a Corporate Net Income Tax (“CNI”) appeal filed by Nextel Communications of the Mid-Atlantic, Inc. (“Nextel”), the Commonwealth Court will consider whether Pennsylvania’s statutory cap on net operating loss (“NOL”)...more

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