News & Analysis as of

C-Corporation Tax Deductions Internal Revenue Code (IRC)

Foster Garvey PC

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

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In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

Rivkin Radler LLP

Private Foundations, Closely Held Businesses, And Distribution Requirements

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“Show Me the Money”- Much has been written in recent months about how well the investment portfolios of private foundations have performed over the last several years. For example, a study conducted by the Council on...more

Lowenstein Sandler LLP

Change of Control: Golden Parachute Rules in the Sale Process

Darren Goodman, Megan Monson, and Taryn Cannataro provide a high-level overview of Section 280G issues that can arise when a private company considers selling (otherwise known as the golden parachute rules), including what...more

Polsinelli

The House Ways and Means Committee Finally Provides Draft Legislative Language for the Tax Changes First Set Forth in President...

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In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...more

Freeman Law

The Tax Court in Brief - November 2020

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....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

Foley & Lardner LLP

IRS Issues Guidance Regarding Net Operating Loss Carryback Waivers and Refunds Under the CARES Act | Blogs | Coronavirus Resource...

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On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...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

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

Rosenberg Martin Greenberg LLP

Loughman Case Illustrates Potential Impact of Entity Choice on Income Tax Liability for Cannabusinesses

Recognition of Internal Revenue Code (“I.R.C.”) § 280E and its potential to limit deductions can have a material impact on the ongoing operation of a cannabusiness. While operational concerns require attention, improper tax...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Latham & Watkins LLP

IRS Issues Proposed Regulations on Business Interest Deduction Limitations

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Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

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On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Burr & Forman

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

Burr & Forman on

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

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

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more

McDermott Will & Emery

The New Deduction for Foreign-Derived Intangible Income

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The 2017 tax reform legislation added section 250 to the Internal Revenue Code, effectively creating a new preferential tax rate for income derived by domestic corporations from serving foreign markets. The new deduction is...more

Mintz

Overview of Recent U.S. Tax Reform Part I – Certain Significant Changes Impacting C-Corporations

Mintz on

On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Real Estate and Construction Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Technology Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

Schwabe, Williamson & Wyatt PC

Summary of Tax Cuts and Jobs Act

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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