Introduction and Background -
Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
8/17/2020
/ Capital Gains ,
Carried Interest ,
Economic Substance Doctrine ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
RICs ,
S-Corporation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Choosing the appropriate type of entity is a multifaceted analysis—one that was impacted by the Tax Cuts and Jobs Act of 2017, or TCJA.
Originally published in Middle Market Growth, the official publication of the...more
Choosing the appropriate type of entity is a multifaceted analysis and is necessarily dependent upon a variety of factors, including business objectives, type of business, desire for cash distributions, and ease of obtaining...more
10/3/2019
/ Business Entities ,
Business Formation ,
Business Taxes ,
C-Corporation ,
Capital Raising ,
Corporate Structures ,
Corporate Taxes ,
Exit Planning ,
Pass-Through Entities ,
Tax Cuts and Jobs Act ,
Tax Rates
Section 199A, enacted in the Tax Cuts and Jobs Act at the end of 2017, allows individuals and certain noncorporate taxpayers to deduct up to 20 percent of qualified business income (QBI) beginning in 2018. QBI generally...more