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Treasury Expands “Safe Harbor” List of Opportunity Zones

The new tax law, known as the Tax Cuts and Jobs Act, allows states, the District of Columbia, U.S. possessions, and Puerto Rico to designate “Qualified Opportunity Zones” to encourage new capital investment in low-income...more

Permanent or Temporary Deferral of Tax on Gains: Opportunity Zones

The new tax law, known as the Tax Cuts and Jobs Act, allows states, the District of Columbia, U.S. possessions, and Puerto Rico to designate Qualified Opportunity Zones to encourage new capital investment in low income census...more

Pennsylvania Department of Revenue Delays Implementation of New Non-Employee Withholding Requirements

After hearing from taxpayers about the significant burden of complying with new Pennsylvania rules requiring personal income tax (PIT) withholding from non-resident service providers who receive IRS Forms 1099-MISC, the...more

Lawsuit Seeks Repeal of 2017 Pennsylvania Tax Act

A group of Pennsylvania fireworks sellers recently filed a complaint in Commonwealth Court, challenging whether the Pennsylvania General Assembly properly enacted Act 43 of 2017 (the 2017 Tax Act). ...more

Pa. Announces Decoupling From Federal Expensing for Corporate Net Income Tax, No Depreciation Allowed for Expensed Property

The Pennsylvania Department of Revenue (the Department) announced in Corporation Tax Bulletin 2017-02 that taxpayers subject to corporate net income tax (CNIT) must add back all bonus depreciation when calculating CNIT...more

Analysis of Key Provisions of the Tax Cuts and Jobs Act

As we are sure you know, H.R. 1, informally known as the Tax Cut and Jobs Act, became law on December 22, 2017. This new law will impact almost all taxpayers. Ballard Spahr's Tax Group has prepared a detailed summary of...more

Federal Tax Reform: An Analysis of the House and Senate Bills

As we are sure you know, both the U.S. House of Representatives and Senate have passed their own versions of tax legislation, known as the Tax Cuts and Jobs Act. The two different bills will be reconciled in a conference...more

Pa. Supreme Court Decision May Materially Shorten Time for Filing Tax Refund Claims

Pennsylvania taxpayers should be aware of the recent decision by the Pennsylvania Supreme Court in Mission Funding Alpha v. Commonwealth, in which the court held that a refund claim is timely only if it is filed within three...more

Pa. 2017 Tax Bill Changes Withholding Requirements, Sales Tax, Corporate Income Tax, and Tax Appeal Procedure

The Tax Bill signed by Governor Tom Wolf on October 30, 2017 made several significant changes to Pennsylvania tax laws that are estimated to generate additional revenue for the Commonwealth. Notable changes under the new law...more

Pennsylvania Supreme Court Declares Dollar-Based NOL Cap Unconstitutional

In a unanimous decision in Nextel Communications of the Mid-Atlantic, Inc. v. Commonwealth, the Pennsylvania Supreme Court affirmed the Commonwealth Court's holding that Pennsylvania's dollar-based cap on corporate net income...more

Unified Framework for Tax Reform

President Donald J. Trump and the "Big Six"—House Speaker Paul Ryan (R-WI), Senate Majority Leader Mitch McConnell (R-KY), Treasury Secretary Steven Mnuchin, White House adviser Gary Cohn, House Ways & Means Committee...more

Deadline Approaches for Phila. Tax Appeals – Increased Assessments & Potential for School District Appeals

The Philadelphia Office of Property Assessment (OPA) has reviewed the assessed values of all commercial and industrial real estate in Philadelphia, and earlier this year, many owners of commercial and industrial real estate...more

Treating Partners as Employees – Overview and Update

Limited liability companies (LLCs) have become the fastest-growing entity choice for businesses in recent years. LLCs provide flexibility in operations and distributions. However, to the surprise of many businesspeople, if an...more

Where Federal Tax Reform Goes, Will State Taxes Follow?

With Republicans in control of both the White House and Congress, comprehensive federal tax reform likely is on the horizon. Both the tax reform plan outlined by President Donald J. Trump during his campaign (the Trump Plan)...more

PA Tax Update: Amnesty Program and SUT Change

Pennsylvania has a tax amnesty program that will run from April 21, 2017, to June 19, 2017. Even with many limitations on participation, this program may provide value to eligible taxpayers who have unfiled Pennsylvania tax...more

Philadelphia Toughens Its Realty Transfer Tax Law

Philadelphia just dramatically tightened its realty transfer tax rules to impose more realty transfer tax. Under the current Philadelphia and Pennsylvania realty transfer tax law, a real estate company owes realty transfer...more

Tax Truths: Volume 1, No. 2 – December 2016

AN ANALYSIS OF TAX LAW PROPOSALS OF THE PRESIDENT-ELECT AND THE HOUSE - President-elect Trump made tax reform a highlight of his campaign, calling for fewer tax brackets, lower individual rates, and reduced corporate tax...more

NJ-PA Income Tax Compact Survives

New Jersey Governor Chris Christie gave Pennsylvania and New Jersey commuters who live in one state and work in the other a Thanksgiving present when he announced that he will not terminate the New Jersey-Pennsylvania income...more

End of NJ-PA Income Tax Compact Would Affect Tax Liability of Thousands of Commuters

Pennsylvania and New Jersey commuters who live in one state and work in the other could face materially increased state tax withholding if a nearly 40-year-old tax reciprocity compact is terminated in January under an...more

Pennsylvania Tax Changes and Tax Amnesty Program

As part of the budget package, the Pennsylvania General Assembly made many significant changes to various Pennsylvania tax laws and the unclaimed property law (including a tax amnesty program) that are estimated to generate...more

Pennsylvania Capital Stock Tax Phased Out; LLCs Now Are the Entity of Choice in PA; Procedure for Filing Final Returns

Until it expired at the end of 2015, Pennsylvania Capital Stock Franchise Tax (CSFT) was imposed on all limited liability companies (LLCs), corporations, joint-stock associations, and business trusts doing business in or...more

Creating a Social Network of Tax Savings: The Use of LLCs in Structuring Philanthropic and Public Good Activities

The use of a limited liability company (LLC) by Mark Zuckerberg and his wife Priscilla Chan as the vehicle for advancing of “philanthropic, public advocacy, and other activities for the public good” has recently received a...more

PA Commonwealth Court Holds NOL Tax Deduction Cap is Unconstitutional, Creating Potential Refund Opportunities

The Pennsylvania Commonwealth Court unanimously held in a 7-0 decision that Pennsylvania's net operating loss (NOL) cap that limits a corporation's ability to deduct NOL carryforwards for corporate net income tax (CNIT)...more

New Rules Adopted for IRS Partnership Tax Audits

The Bipartisan Budget Act of 2015 signed by the President Obama on November 2, 2015, creates a new IRS audit regime for all entities treated as partnerships for federal income tax purposes, including partnerships and limited...more

Payments to LLC Members Subject to Unemployment Compensation Tax

The Commonwealth Court of Pennsylvania held that members of a limited liability company (LLC) are employees of the LLC and are subject to Pennsylvania unemployment tax. The case, King’s Kountry Korner, LLC v. Dep’t of Labor...more

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