News & Analysis as of

Tax Deferral C-Corporation

Bricker Graydon LLP

“S” Corp? Law Change May Make an ESOP More Appealing

Bricker Graydon LLP on

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) made numerous changes to the complex web that makes up U.S. retirement plan laws. Of interest to S corporations that may be considering an employee stock ownership plan (“ESOP”) is...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

Rivkin Radler LLP on

In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

Holland & Knight LLP on

The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Rivkin Radler LLP

The President’s 2024 Federal Budget: “Reforming” the Taxation of High-Income Taxpayers

Rivkin Radler LLP on

The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year. Among other things, the proposed federal budget affords the President an...more

Holland & Hart - The Benefits Dial

Take A Chance On Me? Could We Finally See Legislation Expanding Section 1042 Deferral to S Corp ESOPS?

One of the most popular incentives for small business owners to establish an ESOP (employee stock ownership plan) is the ability to defer tax on the gain they will receive in the sale through the Section 1042 deferral. If...more

Polsinelli

Additional Guidance Issued for President Biden’s American Jobs and American Families Plan

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more

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

THE ACCIDENTAL ENTREPRENEUR PART V video

The Accidental Entrepreneur Series Part V is a great idea for health reimbursement accounts for small business. ...more

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

THE ACCIDENTAL ENTREPRENEUR PART V Podcast

Nowotny On Death and Taxes Podcast episode #27 is Part V in the series The Accidental Entrepreneur and covers using the ideal corporate structure for personal healthcare cost savings....more

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

THE ACCIDENTAL ENTREPRENEUR PART IV

Structuring the family business. This is a solution for every taxpayer to triple a Roth contribution. #assetprotection #estateplanning #retirementplanning #employeebenefits #entrepreneur #taxplanning...more

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

THE ACCIDENTAL ENTREPRENEUR PART IV

Nowotny On Death and Taxes episode #26, The Accidental Entrepreneur Part IV - Creating the Family Pension Plan speaks to a solution for every taxpayer to triple a Roth contribution....more

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

THE ACCIDENTAL ENTREPRENEUR

Best way to structure your business to own multiple businesses in real estate and investment activities. Key benefits: Management and Control, Asset Protection, No FICA and Medicare Withholding and Ability to stagger a tax...more

Farrell Fritz, P.C.

The Federal Anti-Deferral Rules For Foreign Income –Just A Reminder, There’s No Easy Way Out

Farrell Fritz, P.C. on

It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more

Foster Garvey PC

Treasury Delivers Some Good News in a Time When Good News Is Rare

Foster Garvey PC on

On March 13, 2020, President Trump issued an emergency declaration, which in part instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more

BakerHostetler

COVID-19 – Federal and State Tax Updates

BakerHostetler on

Q – Filing of Federal Tax Returns: Must C corporation and individual U.S. federal income tax returns or extensions for the 2019 calendar year be filed by the April 15, 2020, due date?...more

Opportune LLP

How Section 83(i) in the Tax Cuts & Jobs Act of 2017 Benefits Workers

Opportune LLP on

The Tax Cuts and Jobs Act of 2017 (“The Act”) is just over a year old and tax practitioners, taxpayers and commentators are still working to digest the actual effect of many of its sweeping changes. While one of the central...more

Clark Hill PLC

Unique Tax Deferral Opportunity with an ESOP Sale

Clark Hill PLC on

Under a specific set of facts, a C-corporation sale to an ESOP may be able to utilize the tax provision benefits of combining Section 1202 of the Internal Revenue Code of 1986, as amended (the “Code”) and Code Section 1042....more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

Bowditch & Dewey on

BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...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

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