News & Analysis as of November 15, 2024

Taxable Income

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Unconstitutionally Excessive FBAR Penalties? It Depends

Rivkin Radler LLP on 9/18/2024

You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

PA Excludes Dependent Care Assistance from Taxable Income

Ballard Spahr LLP on 3/18/2024

The Commonwealth of Pennsylvania changed its tax treatment of assistance that employers provide for dependent care services – including dependent care flexible spending accounts. Retroactive to January 1, 2023, Pennsylvania...more

Withholding Taxes: Deferred Comp and Services Overseas

Rivkin Radler LLP on 9/7/2023

Approaching Year End- Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than...more

Florida District Court of Appeals hears oral arguments in addback dispute

Eversheds Sutherland (US) LLP on 10/13/2022

On October 11, 2022, the Florida District Court of Appeals, First District held oral arguments on State Farm Mutual Automobile Insurance Company v. Florida Department of Revenue, a case relating to the “add back” to...more

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on 6/14/2022

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

New Final Regulations Revise Rules on the Application of Section 163(j) to CFCs

McDermott Will & Emery on 1/27/2021

As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more

IRS Issues New Section 382 Private Letter Ruling On Identifying Schedule 13 Filers - TAX UPDATE Volume 2019, Issue 3

Troutman Pepper on 7/1/2019

Taxpayers looking to utilize net operating losses (NOLs), excess interest carryovers and certain other tax attributes need to be cognizant of the rules that could limit or eliminate them, including section 382. Section 382...more

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on 2/7/2018

“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

IRS Issues Regulations Affecting Compensation Arrangements at Tax-Exempt Organizations

McDermott Will & Emery on 6/23/2016

On June 21, the IRS issued long awaited proposed regulations under Section 457 of the Internal Revenue Code that affect a broad range of compensation arrangements at tax exempt organizations. If a compensation arrangement is...more

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Income Taxes › Internal Revenue Code (IRC) › Taxable Income

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