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Guest notebook: Bradley partners offer predictions for spring Alabama tax legislation

Each year we are asked to predict the business tax-related bills that died in the last legislative session but will likely be re-introduced in one form or another, as well as the tax issues that we expect to see addressed for...more

IRS Announces Broad Filing and Payment Extensions to Hurricane Victims; Alabama DOR Offers “Case-by-Case” Relief | Insights &...

On October 1, the Internal Revenue Service (IRS) issued a sweeping notice regarding Hurricane Helene relief. The disaster tax relief covers all individuals and businesses affected by Hurricane Helene, “including the entire...more

Pending U. S. Supreme Court Tax Case Could Affect Multistate Contractors

A case on appeal to the U.S. Supreme Court from the South Dakota Supreme Court should be on your watch list. It involves Ellingson Drainage, Inc., a general contractor headquartered in Minnesota that specializes in installing...more

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more

With IRS Partnership Audits Ramping Up, Will More States Enact the MTC Model Statute?

Landmark changes in the federal income tax treatment of partnerships (including multi-member LLCs) became effective in 2018 for many more partnerships than first anticipated. As a result of the Bipartisan Budget Act of 2015,...more

ADOR Grants Extension to Make PTE Tax Election for 2021 Tax Year

Readers may recall that the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) last year as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The...more

Where Are We On The New Elective PTE Tax Regime?

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

Worker Classification Investigations Highlighted

Last week, the Internal Revenue Service issued a polite notice (IR-2021-186) to employers and tax practitioners, as part of National Small Business Week, “to remind… business owners to correctly identify workers as employees...more

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called “SALT Cap” enacted as part of the Tax Cuts and Jobs Act of 2017 that limits the deductibility of...more

The MTC Undertakes an Ambitious Study of Partnership Taxation

On April 27, 2021, the Multistate Tax Commission (MTC) Uniformity Committee voted to accept its Standing Subcommittee’s recommendation to create a work group to study several key issues relating to multistate taxation of...more

Alabama Legislature Codifies Tests for Employee vs. Independent Contractor

On April 19, 2021, Gov. Kay Ivey signed House Bill 408, sponsored by Rep. Wes Kitchens (R-Marshall County/Blount County) and Sen. Clay Scofield (R-Guntersville), into law as Act 2021-226, which will become effective July 1. A...more

Alabama Governor Signs Law Harmonizing Tests for Employee vs. Independent Contractor Status

We have previously written about the growing complications of employee vs. independent contractor classification in the wake of unemployment assistance in the pandemic era, not only for out-of-work employees but, for the...more

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Preserving Independent Contractor Status in the Wake of Non-Employee Unemployment Benefits

In the face of the pandemic over the last year, Congress issued several rounds of unemployment assistance through the CARES Act not only to employees but also to workers classified as independent contractors or self-employed....more

TCJA Reform/CARES Act Bill Introduced in both House and Senate

On January 28, HB 170 and its Senate counterpart, SB 98, were prefiled with the Alabama Legislature and designated as three separate acts: (i) The Alabama Taxpayer Stimulus Freedom Act of 2021, (ii) The Alabama Business Tax...more

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

Alabama Governor Issues Proclamation on Extending State Incentives and Exempting CARES Act Aid

In a welcomed move by the business community, Gov. Kay Ivey on Friday morning issued a proclamation that would exempt certain CARES Act benefits from Alabama income tax and would extend the sunset (expiration) date of two of...more

Final Regulations on Business Donations to Scholarship-Granting Organizations Make for Good Year-End Tax Planning (and Support a...

In August, the U.S. Treasury Department and the Internal Revenue Service issued final regulations on the deductibility of payments of cash or in-kind donations to certain tax-exempt organizations if the donor receives in...more

What Employers Need To Know About The Payroll Tax Deferral Guidance

Following President Trump’s Aug. 8 presidential memorandum directing the Treasury Secretary to defer the withholding and payment of certain employee payroll taxes, the Internal Revenue Service released Notice 2020-65 on Aug....more

COVID-19 Payroll Tax Notice from the IRS Offers Sparse Guidance

Following the August 8, 2020 Presidential Memorandum directing the Treasury Secretary to defer the withholding, deposit, and payment of certain payroll taxes, the Internal Revenue Service released Notice 2020-65 late Friday,...more

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

Is It December Already? Year-End Contribution Strategies for Alabama Taxpayers - SALT Alert: Alabama Edition

As 2019 comes to a close, while most people are busy making holiday plans, dutiful tax advisors and financial planners are burning the midnight oil to minimize their clients’ tax bills that will be due in a few short months....more

A More Viable SALT Cap Workaround? Pass-Through Entity-Level Taxes - Bloomberg Tax

Now that the Treasury Department and Internal Revenue Service have issued ?nal regulations to address at least some variations of so-called ‘‘SALT cap workarounds’’ to the Tax Cuts and Jobs Act’s limitation on individual...more

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

Automotive Suppliers in 2019: New Hope for R&D Credits - Economic Development News

As automotive suppliers begin work on their 2018 tax returns and implement plans for their capital expenditures in 2019, suppliers should look at a potential tax credit to help offset the costs of tooling: the Research and...more

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