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Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, Jan. 3, 2023

Legislative Lowdown - Lawmakers Look to 2023 for Tax Priorities Following Omnibus Passage. On Dec. 29, President Joe Biden signed the nearly $1.7 trillion Consolidated Appropriations Act of 2022 into law, funding the...more

Cadwalader, Wickersham & Taft LLP

Key Features and Ambiguities of the New Corporate Book Minimum Tax

The Inflation Reduction Act of 2022 imposes a 15% corporate Book Minimum Tax (“BMT”) for taxable years beginning after December 31, 2022. The BMT is a 15% tax on certain domestic corporations’ Applicable Financial Statement...more

Brownstein Hyatt Farber Schreck

Taxation and Representation, July 12, 2022

Reconciliation Revival? Ever since Sen. Joe Manchin (D-WV) publicly renounced his support of the House-passed Build Back Better Act (BBBA) in December of last year, the prospects of a reconciliation bill have appeared grim...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, May 24, 2022

Tax Staffers Discuss State of Tax Policy. At a tax conference last week, top officials from the Biden administration and key congressional staffers discussed the latest in tax policy. One panel, which was focused on the...more

Pillsbury - SeeSalt Blog

California Tax Credits and NOL Deductions Are Back! Governor Signs Legislation Reinstating Business Taxpayer Benefits Limited by...

California Governor Gavin Newsom has signed legislation (i.e., S.B. 113) to, among other things, reinstate business tax credits and net operating loss (NOL) deductions originally limited by the enactment of A.B. 85 in 2020....more

Cadwalader, Wickersham & Taft LLP

House Passes Build Back Better Act

Here's a summary of the tax provisions in the Build Back Better Act, as passed by the House. I. Introduction - On November 19, 2021, the House of Representatives passed the Build Back Better Act (the BBBA)....more

Nutter McClennen & Fish LLP

Overriding the Governor, Massachusetts Legislature Gives Pass-Through Entity Owners a Workaround to Federal SALT Deduction Cap

The Massachusetts legislature, overriding Governor Baker’s prior veto, has voted to enact a new elective pass-through entity (“PTE”) tax designed as a way for PTE owners to get out from under the $10,000 cap ($5,000 for...more

Sheppard Mullin Richter & Hampton LLP

California Passes “Workaround” To Federal Limit on State Tax Deduction For Certain Owners of Pass-Through Entities

On July 16, 2021, Governor Newsom signed California Assembly Bill 150 into law, allowing certain owners of passthrough entities to find a way around the current $10,000 federal cap on state and local tax (SALT) deductions for...more

Goodwin

Luxembourg: New Rule Disallowing Deduction On Payments To EU Non-cooperative Countries

Goodwin on

Luxembourg has introduced new legislation disallowing the deduction of interest and royalties owed by Luxembourg corporate taxpayers to associated enterprises established in a jurisdiction included in Annex I of the European...more

Foley & Lardner LLP

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

Foley & Lardner LLP on

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...

Seyfarth Shaw LLP on

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

Ballard Spahr LLP

Pennsylvania 2019 Tax Bill Adds Opportunity Zone Conformity for Personal Income Tax, Adopts New Sales Tax Provisions, and Amends...

Ballard Spahr LLP on

Act 13 of 2019 (Act 13), signed by Governor Wolf on June 28, 2019, made several changes to Pennsylvania tax laws, including the following significant changes. ...more

McDermott Will & Emery

BREAKING NEWS: More States Opt Not to Tax GILTI

McDermott Will & Emery on

This has been an eventful and exciting week for those interested in the states’ taxation of global intangible low-taxed income (GILTI). On Monday, taxpayers received the good news that New York Governor Cuomo signed S. 6615—a...more

Troutman Pepper

IRS Issues Guidance on Section 162(m) Changes

Troutman Pepper on

On August 21, the IRS issued Notice 2018-68 to provide guidance on changes to Internal Revenue Code Section 162(m), enacted by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 162(m) generally limits the tax deduction...more

Pullman & Comley, LLC

Are Connecticut Income Taxes Now Tax Deductible For The Owners Of Pass-Through Entities?

Pullman & Comley, LLC on

June 5, 2018 The Tax Cuts and Jobs Act, which was passed by Congress last year, imposed a $10,000 limit on state and local tax (“SALT”) deductions. ...more

Foodman CPAs & Advisors

Make your connection with the “Top 10” Tax Cut and Jobs Act Changes and be prepared for 2019!

Here are the changes from the Tax Cut and Jobs Act (TCJA) that will impact “most” Individuals when they prepare their 2018 Tax Returns in 2019...more

Troutman Pepper

Focus on New Tax Law: Section 199A Pass-Through Deduction and Restrictions on Interest Deductions Tax Update, Volume 2018, Issue 2

Troutman Pepper on

The Tax Cuts and Jobs Act (2017 Tax Act) significantly modified the treatment of certain deductions for many business taxpayers, including partners and partnerships....more

Carlton Fields

New Tax Law Eliminates 30-Day Safe Harbor Against CFC Status

Carlton Fields on

The recent tax law changes have focused primarily on corporate income tax, and in the international context, mostly on outbound tax matters. However, certain less publicized changes to the Code’s controlled foreign...more

Kramer Levin Naftalis & Frankel LLP

Tax Reform Act Changes to CFC Attribution Rules

The recently enacted tax reform act (the Act) significantly altered the U.S. taxation of foreign income. Perhaps most prominently, the Act allows U.S. corporations to fully deduct (and thus not pay tax on) dividends received...more

Troutman Pepper

Are the New Refundable AMT Credit Carryovers Subject to the Limitation of Section 383? - Tax Update, Volume 2018, Issue 1

Troutman Pepper on

The recently passed Tax Cuts and Jobs Act eliminated the corporate alternative minimum tax (AMT). Before its repeal, a corporate taxpayer that was subject to the AMT was entitled to indefinitely carry forward the AMT taxes...more

Snell & Wilmer

New Tax Act: 2017 Trap for 10% U.S. Owners of Foreign Corporations

Snell & Wilmer on

The Tax Cuts and Jobs Act of 2017 (the “Tax Act”) modifies Section 965 of the Internal Revenue Code (“IRC”) by expanding the definition of “subpart F income” of United States shareholders (“U.S. shareholder”) for the last tax...more

White and Williams LLP

2017 Tax Act: Choice of Entity

We recently prepared an alert on the new 20% qualified business income deduction that was added by the 2017 Tax Act. We have received many questions from our clients and friends about whether, notwithstanding the QBI...more

Orrick, Herrington & Sutcliffe LLP

U.S. Tax Reform Has A Profound Impact On Inbound Investment

The current focus of the international tax community is on the United States, and for good reason. In the midst of a contentious political landscape, months of anticipation, and a decidedly clandestine drafting process, U.S....more

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

Lowndes on

After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more

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