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Corporate Taxes Pass-Through Entities

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Haynsworth Sinkler Boyd, P.A.

House Bill 4087 Revamps Tax Credits for Business Growth and Sustainability

House Bill 4087* (H.4087) advances income tax credits for corporate headquarters, recycling facilities, job development and retraining by amending the South Carolina Code of Laws to update portions of the South Carolina...more

Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more

Williams Mullen

2023 Developments in Virginia Taxation

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A Summary Review of Tax Legislation, Court Decisions, Opinions of the Attorney General and Published Rulings of the Tax Commissioner Published from January 1, 2023 through November 10, 2023....more

PilieroMazza PLLC

Focus on S Corporations, Part 2: Inadvertent Termination of S Corporation Elections

PilieroMazza PLLC on

The IRS recently provided guidance addressing inadvertent terminations of S Corporation (S Corp) status based on existing provisions in corporate documents that remain after a company makes an S Corp election. This can be a...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Williams Mullen

Virginia Dept of Tax Issues Clarifying Guidance for Recent Changes to Pass-Through Entity Tax

Williams Mullen on

The General Assembly enacted legislation (H.B. 1456 and S.B. 1476) during its 2023 Regular Session that removed some of the barriers for qualifying for Virginia’s Pass-Through Entity Tax (PTET) election and altered how PTET...more

Williams Mullen

Virginia’s General Assembly Enacts New Tax Legislation in 2023 (Chart Included)

Williams Mullen on

The table below summarizes the tax legislation enacted by the General Assembly during its 2023 Regular Session and approved by Gov. Youngkin that will become law on or before July 1, 2023. Please note that any legislation...more

Williams Mullen

Increased Flexibility for Pass-Through Entity Tax Election Passes Through General Assembly

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During its 2023 Session, the Virginia General Assembly passed legislation, H.B. 1456 and S.B. 1476, that removes some of the barriers for participating in Virginia’s elective Pass-Through Entity Tax (PTET)....more

Blank Rome LLP

NYC Corporate Tax “Bright Line” Economic Nexus Adopted and NYC Pass-Through Entity Tax Effective Date Moved Up

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New York State Governor Kathy Hochul has signed into law a bill that imposes “bright-line” economic nexus based on in-City receipts, applicable to tax years beginning on or after January 1, 2022, under the New York City...more

Cozen O'Connor

Pennsylvania Enacts Record Tax Reform

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Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, P.L. __. No. 53 (Act 2022-53) (HB 1342) implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions. The bill will:.....more

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

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Elective PTE Income Taxes Payable to Virginia - Beginning July 1, 2022, Virginia’s new law establishing a workaround for the federal income tax limitation on deductions for state and local taxes (SALT) became effective....more

Baker Donelson

SALT Select Developments - April 2022

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Lowndes

Choosing the Right Entity for Your Business

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What is the right entity for your new business? The default answer is often considered to be a corporation, as it provides the owner with protection from business debts and has a lower 21 percent federal tax rate. The...more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Rivkin Radler LLP

Leaving New York – But What About One’s New York Business?

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Goodbye New York- Late last year, the U.S. Census Bureau released data showing population shifts across the country during 2021. According to this information, New York lost 1.8 percent of its population... ...more

BakerHostetler

[Podcast] Phasing Out Corporate Income Taxes - North Carolina Edition

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Matt Hunsaker discusses recent North Carolina tax legislation, including phase-out/phase-down of corporate and individual income tax rates, an elective passthrough entity SALT cap workaround, and simplification of the...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

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

Foster Garvey PC on

Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Billionaires Tax

On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more

Nutter McClennen & Fish LLP

Overriding the Governor, Massachusetts Legislature Gives Pass-Through Entity Owners a Workaround to Federal SALT Deduction Cap

The Massachusetts legislature, overriding Governor Baker’s prior veto, has voted to enact a new elective pass-through entity (“PTE”) tax designed as a way for PTE owners to get out from under the $10,000 cap ($5,000 for...more

McGuireWoods LLP

Build Back Better Act: House Ways and Means Committee Tax Proposals – Key Issues for Corporations, Passthrough Entities, and...

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On Sept. 15, 2021, the Ways and Means Committee of the U.S. House of Representatives approved a proposed tax legislative package (the “W&M proposal”) to the Build Back Better Act reconciliation bill (the “Act”), which...more

Cadwalader, Wickersham & Taft LLP

Wyden Proposes Expansion of Pass-Through Deduction

On July 20, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) proposed legislation to modify the 20% deduction allowed to investors in certain pass-through businesses under Section 199A....more

Burr & Forman

The Death of S Corporations?

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Corporations, limited liability companies, and certain other business entities can make an election with the Internal Revenue Service to be taxed under Subchapter S of the Internal Revenue Code.  If such an election is made,...more

Kilpatrick

4 KEY TAKEAWAYS: Mid-Year Tax Update

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On June 22nd, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the federal...more

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