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C-Corporation Pass-Through Entities

Foodman CPAs & Advisors

Pass-Through Entities are Under Scrutiny by IRS

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On 10/22/24, the IRS announced that is has officially commenced operations of the newly established pass-through field operations unit within its Large Business and International (LB&I) division, which was announced last...more

Holland & Knight LLP

A Look at Search Funds and Section 1202 Qualified Small Business Stock

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Search Funds should consider the availability of the tax benefits of Section 1202 in connection with their acquisitions. The upside, if properly structured, can be significant. Section 1202 has gained popularity likely due to...more

Rivkin Radler LLP

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

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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

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

Rivkin Radler LLP

Some Observations On Recent Conversions of Partnerships to “C” Corporations

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Decisions- It is often the case that the optimal form of legal entity through which a business should operate, at least for income tax purposes, will depend in part upon the stage of its life cycle in which the business...more

J.S. Held

Don’t Double Tax Your Business: How The PTE Tax Can Impact the Valuation of Pass-Through Entities

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Taxes can have a significant impact on the value of a business. Pass-through entities such as S-Corporations and partnerships generally do not pay any taxes since the income is passed through to the individual shareholder or...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

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I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act targets carried interests

On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more

Kerr Russell

Tax Tips for 2022

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All businesses, whether large or small, should frequently evaluate strategies for minimizing their overall tax burden. Here are a few tips that businesses may consider implementing to achieve such tax savings. ...more

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

Arkansas's Answer to the SALT Cap for Business Owners: The Arkansas Pass-Through Entity Tax Act

The Tax Cuts and Jobs Act of 2017 (The “TCJA”) imposes a $10,000 cap on the amount an individual may deduct for federal tax purposes for the payment of state and local income, property and sales taxes (referred to as “SALT”)....more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...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

Rivkin Radler LLP

Tax Distributions As Fraudulent Conveyances?

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The Calm Before? I’m confused. For better or worse, I’m pretty sure that I am not alone. Last week, in a letter addressed to the American people, forty-six of the fifty Republicans in the U.S. Senate indicated they...more

Smith Anderson

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

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With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Morrison & Foerster LLP

Legal Structures To Optimize Private Investor Impact Strategy

How can legal structures help investors maximize the impact of their investments? Below, read more about key ESG concepts and best practices for stakeholders and investors to consider moving forward...more

Bradley Arant Boult Cummings LLP

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Farrell Fritz, P.C.

The Loss Of The Favorable Capital Gain Rate, The Exclusion Of Gain under Section 1202, And The Incorporation Of The Partnership

Farrell Fritz, P.C. on

If the Democrats Win- Science has not established – at least to my knowledge – any correlation between the pre-election year-end activities of individual business owners, on the one hand, and election outcomes, on the...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

Carlton Fields

Ledgers and Law: Start With an Ending in Mind When Building a New Business

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Starting a business is not for the faint of heart. Your best chance at survival and success is to plan out the life cycle of your company from the beginning and how you are going to exit at the end. The decisions you make...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

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In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...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

Holland & Knight LLP

Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses

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The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border tax regime. Many of the TCJA's international tax reforms that have received considerable attention...more

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