In this ninth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that may permit individual taxpayers to deduct the interest incurred with respect to their...more
8/8/2025
/ Adjusted Gross Income ,
Automotive Loans ,
Federal Taxes ,
Income Taxes ,
Interest Payments ,
Internal Revenue Code (IRC) ,
IRS ,
One Big Beautiful Bill Act ,
Refinancing ,
Reporting Requirements ,
Tax Code ,
Tax Deductions ,
Tax Policy ,
Tax Reform
In this eighth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that impact the taxation of worker moving expenses....more
8/6/2025
/ Deductible Expenses ,
Employee Benefits ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
One Big Beautiful Bill Act ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Policy ,
Tax Reform
In this seventh installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss provisions of the Act that impact the deductibility of individual charitable gifts under Code Section 170....more
8/1/2025
/ Adjusted Gross Income ,
Charitable Deductions ,
Federal Taxes ,
Gifts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
One Big Beautiful Bill Act ,
Tax Code ,
Tax Deductions ,
Tax Planning ,
Tax Policy ,
Tax Reform
In this sixth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that impacts the deductibility of corporate charitable gifts under Code Section 170(b)(2)(A)....more
7/30/2025
/ C-Corporation ,
Charitable Deductions ,
Corporate Taxes ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
One Big Beautiful Bill Act ,
Tax Code ,
Tax Deductions ,
Tax Policy ,
Tax Reform
In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more
7/23/2025
/ Alternative Minimum Tax ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Federal Taxes ,
Gain Exclusion ,
Income Taxes ,
Inflation Adjustments ,
Internal Revenue Code (IRC) ,
IRS ,
One Big Beautiful Bill Act ,
Qualified Small Business Stock ,
Shareholders ,
Small Business ,
Tax Benefits ,
Tax Code ,
Tax Legislation ,
Tax Planning ,
Tax Policy ,
Tax Reform
In this fourth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), Steve Nofziger and I discuss a provision of the Act that impacts pass-through business entities and their owners, Code Section...more
7/18/2025
/ Business Taxes ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
One Big Beautiful Bill Act ,
Partnerships ,
Pass-Through Entities ,
Qualified Business Income ,
S-Corporation ,
Section 199A ,
Sole Proprietorship ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
Trump Administration
In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy of...more
7/16/2025
/ Federal Taxes ,
Gambling ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
One Big Beautiful Bill Act ,
Tax Code ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Policy ,
Tax Reform
In this second installment of our multi-part series on the One Big Beautiful Bill Act (the “Act”), my colleague David Knutson and I discuss the changes made by the Act to the federal estate and gift tax regime....more
7/11/2025
/ Estate Planning ,
Estate Tax ,
Estate-Tax Exemption ,
Federal Taxes ,
Generation-Skipping Transfer ,
Gift Tax ,
Gift-Tax Exemption ,
Income Taxes ,
Internal Revenue Code (IRC) ,
New Legislation ,
One Big Beautiful Bill Act ,
Tax Code ,
Tax Exemptions ,
Tax Planning ,
Tax Policy ,
Tax Rates ,
Tax Reform ,
Trump Administration ,
Wealth Management
On July 1, 2025, the One Big Beautiful Bill Act, H.R.1 – 199th Congress (2025-2026) (the “Act”) was passed in the U.S. Senate (“Senate”). On July 3, 2025, it was passed in the U.S. House of Representatives (“House”) and...more
7/9/2025
/ Adjusted Gross Income ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Local Taxes ,
One Big Beautiful Bill Act ,
SALT ,
State Taxes ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Policy ,
Tax Reform ,
Tax Returns ,
Trump Administration
As reported on May 16, 2025, the SALT cap proposal contained in the legislation that was pending in the U.S. House of Representatives (“House”) aimed at, among other things, dealing with the expiring provisions of the Tax...more
As reported on May 13, 2025, several changes to the Washington state tax laws were passed by lawmakers and delivered to the desk of Governor Ferguson in late April, awaiting his signature to make them law. In the aggregate,...more
5/27/2025
/ B&O Tax ,
Capital Gains Tax ,
Gas Taxes ,
Income Taxes ,
Sales & Use Tax ,
State Taxes ,
Tax Credits ,
Tax Deductions ,
Tax Increases ,
Tax Legislation ,
Tax Rates ,
Tax Revenues ,
Transportation Industry ,
Washington
Oregon House Bill 3115 (“HB 3115”) was sponsored by Representatives John Lively (D) and Kimberly Wallan (R). It was co-sponsored by Representatives Tom Anderson (D), David Gomberg (D) and Nathan Sosa (D).
HB 3115 was...more
Prior to the Tax Cuts and Jobs Act (“TCJA”), there was no direct limitation on an individual taxpayer’s deduction of his or her state and local taxes (“SALT”) on the federal individual income tax return. Of course, for...more
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
4/23/2025
/ Business Expenses ,
Business Losses ,
Department of Revenue ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Oregon ,
Section 162 ,
Section 183 ,
State Taxes ,
Tax Audits ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Litigation
Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more
4/4/2025
/ Business Losses ,
Business Ownership ,
Change of Ownership ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Ownership Interest ,
S-Corporation ,
Shareholders ,
Tax Code ,
Tax Credits ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Treasury Regulations
In this Part XV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a potential advantage that the S corporation has over the C corporation.
The Patient Protection and Affordable Care...more
In this Part XIV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a narrow aspect of Subchapter S that is often ignored or forgotten. An S corporation is not always a mere extension of...more
The Wild Journey -
I am taking time out from my multi-part series on Subchapter S to report on the Washington capital gains tax. As you know, I have reported in several prior blog posts on the numerous challenges...more
Basic Rules -
IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer.
There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more
The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in...more
In this Part XII of my multi-part series on some of the not-so-obvious aspects of S corporations, I explore a consistent theme – taxpayers lose fights with taxing authorities when they fail to maintain adequate records....more
10/16/2024
/ Business Records ,
Failure To Maintain ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Joint Tax Returns ,
Recordkeeping Requirements ,
S-Corporation ,
Tax Court ,
Tax Credits ,
Tax Planning ,
Treasury Regulations
When considering converting a C corporation to an S corporation, tax advisers and taxpayers need to pay careful attention to the many perils that exist. Failure to pay close attention to the road in this area could result in...more
8/21/2024
/ C-Corporation ,
Capital Gains Tax ,
Corporate Conversions ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Passive Activity ,
S-Corporation ,
Shareholder Distributions ,
Shareholders ,
Tax Planning
Unlike the rules contained in Subchapter K surrounding partnership distributions, which tend to be somewhat complex, the distribution rules contained in Subchapter S are fairly straightforward. Nevertheless, from time to...more
As reported last week, opponents of the Washington state capital gains tax, after ultimately losing in the courts to have the legislation stricken as unconstitutional, decided to take the matter to the voters. They have...more
I have reported in several prior blog posts the significant events impacting the newly enacted Washington state capital gains tax. The turbulent ride of this legislation continues!...more