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
New York Attorney General Barbara Underwood and New York Governor Andrew Cuomo announced today that the state of New York, joined by the states of Connecticut, New Jersey and Maryland, have instituted a lawsuit against the...more
7/18/2018
/ 16th Amendment ,
Constitutional Challenges ,
Federal Taxes ,
Governor Cuomo ,
Income Taxes ,
IRS ,
Itemized Deductions ,
SALT ,
Secretary of the Treasury ,
State Attorneys General ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tenth Amendment ,
Trump Administration
The Tax Cuts and Jobs Act (“TCJA”) will significantly impact merger and acquisition (“M&A”) activity. Although billed as tax reform, the TCJA did not reform or simplify the Internal Revenue Code (“Code”).
Virtually none of...more
4/9/2018
/ Acquisitions ,
Alternative Minimum Tax ,
Commercial Real Estate Market ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EBITDA ,
Foreign Acquisitions ,
Foreign Corporations ,
International Tax Issues ,
Mergers ,
Net Operating Losses ,
S-Corporation ,
Section 1031 Exchange ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
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
The Tax Cuts and Jobs Act (“TCJA”) creates the need for tax planning with respect to several major life-changing activities individuals may encounter, including marriage, divorce, home ownership, casualty losses, medical...more
3/9/2018
/ Alimony ,
Alternative Minimum Tax ,
Child Tax Credit ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
Local Taxes ,
Medical Expenses ,
Mortgage Interest ,
Personal Exemptions ,
Standard Deduction ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Tax Refunds ,
Trump Administration
BACKGROUND -
The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more
2/28/2018
/ Affordable Care Act ,
Compensation & Benefits ,
Covered Employees ,
Deferred Compensation ,
Employee Relocations ,
Fringe Benefits ,
Income Taxes ,
Individual Mandate ,
Internal Revenue Code (IRC) ,
IRS ,
Meal and Entertainment Expenditures ,
Medical Leave ,
Paid Family Leave Law ,
Pre-Employment Agreements ,
Repeal ,
Tax Benefits ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Transportation Costs ,
Trump Administration
“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
As indicated at the end of 2017, I intend to provide our readers with an in-depth review of the Tax Cuts and Jobs Act (“TCJA”). With the help of two of my colleagues, Steven Nofziger and Miriam Korngold, we will do this in a...more
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
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 this blog post, we focus our attention on the likely timing...more
Earlier this week, United States Tax Court Judge Richard T. Morrison ruled, in the case of Emmanuel A. Santos v. Commissioner, T.C. Memo 2016-100 (May 17, 2016), that the government will not pay the cost of a taxpayer...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
As a general rule, in accordance with IRC § 162(a), taxpayers are allowed to deduct, for federal income tax purposes, all of the ordinary and necessary expenses they paid or incurred during the taxable year in carrying on a...more
10/26/2015
/ Apportionment ,
Books & Records ,
Controlled Substances ,
Controlled Substances Act ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Returns