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Tax Planning Business Taxes

Kilpatrick

5 Key Takeaways - Income Tax Jeopardy! A Potpourri of Hot Topics

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Kilpatrick’s David Hughes recently participated in a panel discussion at the Taxpayers’ Federation of Illinois annual state and local tax conference in Rolling Meadows, Illinois. David’s session, “Income Tax Jeopardy! A...more

PilieroMazza PLLC

Corporate Transparency Act, Part 2: Exempt Status, Physical Office, Dissolved and Tribal Entities, and Beneficial Ownership...

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The Corporate Transparency Act (CTA), which came into effect on January 1, 2024, has significant implications for government contractors, tribal entities, and commercial businesses. If you formed an entity before January 1,...more

McDermott Will & Emery

Family Office Symposium 2024 | Key Takeaways

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McDermott’s Family Office Symposium 2024 gathered more than 275 family office executives to explore creative solutions to navigate complexity and gain fresh perspectives on the challenges they face. Over two days,...more

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

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

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

Hooked on a Feeling! The Benefits of 501(c)(4) Charitable Organizations

I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more

Bradley Arant Boult Cummings LLP

It Ain’t Over ‘til It’s Over: IRS reminds Taxpayers That Section 280E Applies to Marijuana Companies Until Rescheduling Becomes...

While marijuana advocates celebrate the potential rescheduling of marijuana from Schedule I to Schedule III, the taxman has made clear that marijuana remains a Schedule I substance subject to Section 280E of the Internal...more

Barnea Jaffa Lande & Co.

New Israeli Court Ruling on Artificial Transactions

A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more

ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

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When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

ASKramer Law

Business Taxation of Hedging Transactions Part I: Hedging Risks

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Enterprise Risk Management is widely used in many industries and businesses. Risk managers use increasingly sophisticated approaches, methods, analytics, and frameworks to manage complex, interrelated, and interconnected...more

McDermott Will & Emery

Weekly IRS Roundup March 4 – March 8, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4, 2024 – March 8, 2024. ...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part IV – Suspended...

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This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more

McDermott Will & Emery

Weekly IRS Roundup February 12 – February 16, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 12, 2024 – February 16, 2024. ...more

Baker Donelson

Summaries Released of Select Informal Conference Decisions

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The Tennessee Department of Revenue (Department) recently posted certain selected informal conference summaries which provides taxpayers with insight into how the Hearing Office will address various issues arising under...more

Freeman Law

What to Know When Selling the Assets of a Business

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In an “applicable asset acquisition,” the sale of the assets of a business may be subject to certain allocation and reporting requirements for federal income tax purposes. It’s essential for the seller and purchaser to be...more

Williams Mullen

[Event] Winter Tax Forum 2024 - January 31st, Richmond, VA

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Join Williams Mullen partners for our in-person Winter Tax Forum on Wednesday, January 31, 2024. Our speakers, Farhad Aghdami, Jenny Connors, Conrad Garcia and Beth Hungate-Noland will present on partnership aggregators and...more

Winthrop & Weinstine, P.A.

The Employee Retention Tax Credit: IRS Developments and Strategy for Taxpayers

The Employee Retention Tax Credit (“ERTC”), under the CARES Act, is a refundable tax credit filed against a company’s payroll taxes. The ERTC was enacted to incentivize employers to maintain their employee base during the...more

McDermott Will & Emery

Weekly IRS Roundup January 1 – January 5, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 1, 2024 – January 5, 2024. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials

Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more

Bodman

Michigan Flow-Through Entity Tax Election Deadline Approaching

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Michigan taxpayers with interests in calendar year-end S corporations and partnerships should take note: the deadline to make a new “flow-through” entity tax (“FTE tax”) election for 2024 is approaching, and it occurs prior...more

Latham & Watkins LLP

New IRS Unit Leverages AI to Step Up Partnership Audits; Hundreds of New Inquiries Expected

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The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more

Miller Canfield

IRS Announces Denials of Employee Retention Credit

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As described in our October 24 article “IRS Offers Forgiveness for Erroneous Employee Retention Credit Claims” the IRS has increased scrutiny on claims for the Employee Retention Credit (“ERC”). The IRS halted processing...more

Verrill

2023 Massachusetts Tax Update

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Massachusetts Estate Tax: For decedents dying on or after January 1, 2023, there is no Massachusetts estate tax for an estate under $2,000,000. The law does not adjust the filing threshold so state tax returns may still be...more

McDermott Will & Emery

Weekly IRS Roundup September 21 – September 27, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2023 – September 27, 2023...more

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