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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
On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more
This client alert is part of a special series on the Tax Cuts and Jobs Act and related changes to the tax code, where Blank Rome’s lawyers share their analysis of different provisions in the Act and how they may affect you...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
Our last three posts focused on those provisions of the Tax Cuts and Jobs Act[1] that apply specifically to pass-through entities, including partnerships and S corporations. Today, we turn our attention to domestic...more
Now that the 2017 tax reform act is law, private equity and M&A professionals must grapple with its sweeping changes and reconcile the new provisions with how they do business. This On the Subject summarizes important...more
President Trump signed into law a major overhaul of the US tax system. The corporate tax rates have changed from a system of graduated tax rates up to 35% to a flat tax on corporate profits of 21%. The alternative minimum tax...more
Long a priority of the Republican Party, the final tax cut bill includes significant simplification and lowering of the taxes paid by corporations. The bill eliminates the corporate Alternative Minimum Tax, creates a new tax...more
In the early hours of Saturday morning, the U.S. Senate passed the Tax Cuts and Jobs Act (H.R. 1) (the “Senate bill”), just over two weeks after the U.S. House of Representatives passed its own version of the same legislation...more
On September 27, 2017, the Secretary of the Treasury, the Director of the National Economic Council, the Chair of the U.S. House Ways and Means Committee, the Chair of the U.S. Senate Finance Committee, the Speaker of the...more
On September 28, the Trump Administration and the Republican Congressional leadership announced their framework for tax reform. Many of the crucial details have been left for Congress to decide, but the major points of the...more