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Business Taxes Pass-Through Entities Corporate Taxes

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

PilieroMazza PLLC

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

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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

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

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

Proskauer - Tax Talks

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

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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

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

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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

Sheppard Mullin Richter & Hampton LLP

California Passes “Workaround” To Federal Limit on State Tax Deduction For Certain Owners of Pass-Through Entities

On July 16, 2021, Governor Newsom signed California Assembly Bill 150 into law, allowing certain owners of passthrough entities to find a way around the current $10,000 federal cap on state and local tax (SALT) deductions for...more

Wyrick Robbins Yates & Ponton LLP

Nine Biden Tax Proposals to Know as We Near Election Day

We’re roughly a month from Election Day, and I think it’s safe to say many Americans have strong opinions about who should be our President for the next four years.  I also think it’s safe to say taxes are not the top...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

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On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

Morgan Lewis

NJ Enacts Elective Pass-Through Business Tax to Limit Federal Cap Impact on SALT Deduction

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New Jersey recently enacted the “Pass-Through Business Alternative Income Tax Act,” which allows pass-through businesses with at least one member liable for the New Jersey gross income tax to make an election to pay income...more

Troutman Pepper

Choice of Entity Considerations Post-Tax Reform: Corporation or Flow-Through Entity?

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Choosing the appropriate type of entity is a multifaceted analysis and is necessarily dependent upon a variety of factors, including business objectives, type of business, desire for cash distributions, and ease of obtaining...more

Burr & Forman

Section 199A – The Decision to Aggregate

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Farrell Fritz, P.C.

Is Timing Everything? Only Time Will Tell: Small Business Stock And The Reduced Corporate Tax Rate

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The Tax Law- In theory, the primary purpose of the income tax, as a body of law, is to raise from the governed the resources that the government requires in order to perform its most basic functions. However, as society...more

Rosenberg Martin Greenberg LLP

Section 199A: How "Reasonable Compensation" Will Be Defined and How it May Impact the QBI Deduction

From its inception, Section 199A made it fairly clear that the deduction for qualified business income (“QBI”) would not apply to all income in respect of pass-through businesses. Aside from limitations dependent on the...more

Burr & Forman

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

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Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Verrill

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

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In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

White and Williams LLP

2017 Tax Act: Choice of Entity

We recently prepared an alert on the new 20% qualified business income deduction that was added by the 2017 Tax Act. We have received many questions from our clients and friends about whether, notwithstanding the QBI...more

Blank Rome LLP

2017 New Tax Law: Pass Through Provisions

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On December 20, 2017, Congress passed its comprehensive tax reform bill, the Tax Cuts and Jobs Act (“the Act” or “the Bill”), which was signed into law by President Trump on December 22, 2017. The Bill represents one of the...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

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Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The New Deduction for Pass-Through Income (or How Congress Failed at Tax Simplification)

One of the more significant changes in the recently enacted Tax Cuts and Jobs Act is new Internal Revenue Code Section 199A, Qualified Business Income. Although touted as providing tax simplification, the Tax Cuts and Jobs...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

Sheppard Mullin Richter & Hampton LLP

Real Estate Aspects of Tax Reform

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax laws will have a significant impact upon...more

Tarter Krinsky & Drogin LLP

Pass-Through Income - What's All the Fuss About?

The new year brings new tax laws, and one of the most prominent changes for many will be a new deduction for pass-through income. Beginning in 2018, there will be an income tax deduction of 20% for "Qualified Business...more

Foley & Lardner LLP

Tax Planning Strategy Under the New Tax Cuts and Jobs Act

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Late in 2017, the Tax Cuts and Jobs Act was passed. It will take effect in 2018. The Tax Cuts and Jobs Act eliminated or limited a number of different tax preference items...more

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