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Tax Deductions Limited Liability Company (LLC)

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

International Lawyers Network

Establishing a Business Entity in the United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the...more

Mintz - Employment Viewpoints

Show Me The Money! Trends in Executive Compensation

As the calendar inches closer to 2024, a pivotal concern looms large in the minds of most employees: cash bonuses. However, for executives, especially those who work for private companies that may be involved in a...more

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

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Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more

Rivkin Radler LLP

The Transaction That Failed – Tax Treatment of Termination Fees

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Deal Costs, Generally- Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more

International Lawyers Network

Establishing A Business Entity In The United States (Updated)

1. Choosing the Right Legal Structure - 1.1 Introduction - Establishing a business entity in the United States can be an important strategic step for any international company that wants to avail itself of the world’s...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

Kerr Russell

Michigan Enacts SALT Cap Workaround For Pass-Through Entities

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On December 20, 2021, Governor Gretchen Whitmer signed legislation (H.B. 5376) allowing owners of S corporations and partnerships (including limited liability companies taxed as partnerships) to pay their state and local...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

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Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Freeman Law

The Tax Court in Brief - February 2021 #3

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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. The Week of February 15 – February 19, 2021 - Kramer v. Comm’r, T.C....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

Bowditch & Dewey

Are Your Unreimbursed Partner’s Expenses Deductible?

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Since the Tax Cuts and Job Act of 2017 (TCJA) was passed, a little-known deduction for unreimbursed partner’s expenses (UPE) has taken on more significance. Partner’s in partnership and members of an LLC often incur...more

Farrell Fritz, P.C.

Can A Partnership’s Payment To A Partner For Services Not Be Treated As Such For Purposes Of Sec. 199A?

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Memory Lane- You may recall how clear it became, as the bill that would become the Tax Cuts and Jobs Act (“TCJA”) moved through Congress in late 2017, that C corporations were about to realize a number of tax benefits,...more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

Cole Schotz on

The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

White and Williams LLP

IRS to Allow “Workaround” to Deduction Limits for State and Local Income Taxes

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The Tax Cuts and Jobs Act (2017 Tax Act) limited the deduction of state and local taxes to $10,000 for individuals. Several states, including Connecticut, New Jersey and Maryland, have passed legislation that imposed income...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...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

Dickinson Wright

Recent Case Sheds Light on When a Trade or Business Begins

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A recent Tax Court summary opinion, Smith v. Commissioner, T.C. Summ. Op. 2019-12, sheds light on when a business becomes an active trade or business for purposes of the deduction for “start-up expenditures” available under...more

Pullman & Comley, LLC

Waiver Of Penalties And Interest In Connection With 2018 Pass-Through Entity Tax

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In the Spring of 2018, the Connecticut Legislature adopted a Pass-Through Entity Tax (the “PE Tax”), which imposes a 6.99% tax on pass-through entities (partnerships, limited liability companies and S-corporations). The PE...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

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Does It Apply To Rental Real Estate Activities?

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted a 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

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

Burr & Forman

The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners: Employee Leasing May Help

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted a 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

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