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Holland & Knight LLP

Se anula límites adicionales a distribución proporcional de retenciones en Colombia

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Mediante reciente Sentencia 26085 del 30 de agosto de 2024, el Consejo de Estado de Colombia declaró la anulación parcial de la doctrina de la Dirección de Impuestos y Aduanas Nacionales (DIAN) que concluía que el socio...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

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

Nutter McClennen & Fish LLP

Enhancing Investment Returns by Addressing Book/Tax Differences

Many business entities are LLCs. Usually, LLCs are taxed as partnerships. Like all tax partnerships, LLCs are subject to partnership tax rules. Applying those rules to your advantage can greatly enhance investment returns....more

Vinson & Elkins LLP

[Webinar] All in the Family: Applying the Business Interest Expense Limitation Within Groups - September 30th, 12:00 pm - 1:00 pm...

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The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

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As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Farrell Fritz, P.C.

Current Distributions & Partial Liquidations: Corps vs. Partnerships

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“You Must Choose, But Choose Wisely.” The enactment of the Tax Cuts and Jobs Act, and its undeniable bias in favor of C corporations, has spurred the owners of many closely held businesses, along with their advisers, to...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

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

Verrill

Tax Alert: Understanding the New Pass-Through Business Deduction Rules Under Code Section 199A

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Due to the significant changes to the Internal Revenue Code (“Code”) made by the Tax Cuts and Jobs Act (“Tax Act”) at the end of last year, the Department of the Treasury has been very busy issuing guidance and proposed...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Burr & Forman

New IRS §199A Proposed Regulations Provide Guidance On “Qualified Business Income”: What Income is “In” and What Income is “Out”...

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The IRS has issued Proposed Regulations now under the new Section 199A 20% profit deduction for pass-through entities. The Proposed Regulations provide important guidance on the definition of “Qualified Business Income” –...more

Alston & Bird

Certain Banks Qualify for the 20% Pass-Through Deduction

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Our Federal Tax Group highlights Section 199A and the IRS’s new proposed regulations that allow pass-through businesses to deduct up to 20% of their qualified business income....more

Burr & Forman

IRS Issues New Proposed Regulations on Section 199A 20% Deduction for Pass-Through Businesses

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The Internal Revenue Service yesterday issued its much-anticipated Proposed Regulations on the new Section 199A 20% deduction for owners of pass-through business entities. This important deduction was created under the 2017...more

Foster Garvey PC

Newly Proposed IRS Regulations Put a Monkey Wrench in Plans by Service Businesses Seeking IRC § 199A Deduction

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The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more

Butler Snow LLP

Congress Fixes “Grain Glitch” Error in 199A

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On March 23, the Consolidated Appropriations Act (the “Appropriations Act”) was signed into law by President Trump. Included in the Appropriations Act were certain tax law provisions, including technical corrections to 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

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

Mayer Brown

What Is the Impact of Tax Reform on US Wind Tax Equity Deals?

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A Word About Wind has published our article What Is the Impact of Tax Reform on US Wind Tax Equity Deals? in its blog (subscription required) and newsletter. ...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

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On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Burr & Forman

The New 20% Pass-Through Deduction: Can Real Estate Owners Claim It?

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The new 20% deduction for “pass-through” business owners under the Tax Cuts and Jobs Act is raising many questions from owners of real estate-related businesses. Can these owners qualify for this important deduction, and...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

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