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
8/9/2018
/ Anti-Abuse Rule ,
Business Income ,
Business Ownership ,
Business Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
S-Corporation ,
Sole Proprietorship ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
3/28/2018
/ Business Taxes ,
Charitable Donations ,
Charitable Organizations ,
Colleges ,
Endowment Funds ,
Estate Tax ,
Excise Tax ,
Executive Compensation ,
Fringe Benefits ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Standard Deduction ,
Tax Benefits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Exemptions ,
Tax Planning ,
Tax Reform ,
Trump Administration ,
Universities ,
Unrelated Business Income Tax
“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
2/7/2018
/ Borrowers ,
Business Expenses ,
Business Taxes ,
C-Corporation ,
Carry Forward ,
Carve Out Provisions ,
Corporate Taxes ,
Debt ,
EBITDA ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Lenders ,
Net Operating Losses ,
Partnerships ,
Pass-Through Entities ,
S-Corporation ,
Shareholders ,
Small Business ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Taxable Income ,
Termination
BACKGROUND -
The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more
1/30/2018
/ Business Income ,
Business Taxes ,
C-Corporation ,
Compensation ,
Deduction Limitations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Landlords ,
Limited Liability Company (LLC) ,
Pass-Through Entities ,
Property Owners ,
S-Corporation ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Penalties ,
Tax Reform ,
Threshold Requirements ,
Trump Administration ,
W-2 ,
Wage and Hour
Judge Ruwe ruled in Jeremy M. Jacobs and Margaret J. Jacobs v. Commissioner, 148 T.C. 24 (June 26, 2017), that a free lunch may exist today under Federal tax law. In this case, the taxpayers, owners of the Boston Bruins of...more
7/7/2017
/ Athletes ,
Business Expenses ,
Business Taxes ,
Collective Bargaining Agreements (CBA) ,
De Minimis Claims ,
Hotels ,
Internal Revenue Code (IRC) ,
IRS ,
Meals-Gifts-and Entertainment Rules ,
Non-Discrimination Rules ,
Payroll Taxes ,
Sports ,
Tax Deductions ,
Traveling Employee
For more than a year, I have been discussing the potential that Oregon lawmakers will pass a corporate gross receipts tax. On May 26, 2017, we discussed recent events that would lead a reasonable person to believe that the...more
After Oregon Measure 97’s drubbing at the polls in November 2016, for many, it suggested the quashing of any notion of a gross receipts tax in the state. For Oregon Senator Mark Hass (D) and Representative Mark Johnson (R),...more
On April 11, 2017, we discussed what constitutes Tax Reform. On April 24, 2017, we explored the process by which Tax Reform will likely be created by lawmakers. In our May 3, 2017 blog post, we focused on the likely timing...more
5/19/2017
/ Alternative Minimum Tax ,
Anti-Avoidance ,
Business Taxes ,
Carried Interest ,
Corporate Taxes ,
Estate Tax ,
Gift Tax ,
Income Taxes ,
International Tax Issues ,
Itemized Deductions ,
Manufacturers ,
Pass-Through Entities ,
Popular ,
Presidential Memorandum ,
Standard Deduction ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacts: (i) the manner in which entities taxed as partnerships will be...more
As reported in my November 2015 blog post, in accordance with Internal Revenue Code (“Code”) Section 280E, taxpayers (for purposes of computing federal taxable income) are prohibited from deducting expenses related to the...more
Background -
Actual or constructive receipt of the exchange funds during a deferred exchange under IRC Section 1031 totally kills an exchange and any tax deferral opportunity. Treasury Regulation Section 1031(k)-1(f)(1)...more