News & Analysis as of

Internal Revenue Service Pass-Through Entities Tax Reform

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Venable LLP

SALT Alert: Senate Tax Bill Targets SALT Cap Workarounds, Including New Limits on PTET Deductions

Venable LLP on

On June 16, 2025, the Senate Finance Committee released a draft package that includes a major provision aimed at curbing the use of state pass-through entity taxes (PTETs) to bypass the federal $10,000 cap on state and local...more

Pillsbury Winthrop Shaw Pittman LLP

Parallel Play: The U.S. Senate Finance Committee Releases Its Version of the “Big, Beautiful Bill”

When toddlers engage in parallel play, the children play adjacent to each other, but do not try to influence one another’s behavior. Apparently, parallel play can extend well into adulthood and to the writing of federal...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

Whiteford on

In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

Polsinelli on

Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

Sands Anderson PC on

Elective PTE Income Taxes Payable to Virginia - Beginning July 1, 2022, Virginia’s new law establishing a workaround for the federal income tax limitation on deductions for state and local taxes (SALT) became effective....more

Proskauer - Tax Talks

Proposed Regulations Regarding the Aggregate Treatment for Pass-Through Owners of PFIC Stock

Proskauer - Tax Talks on

On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more

Cadwalader, Wickersham & Taft LLP

Wyden’s Billionaires Tax

On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more

Burr & Forman

The Death of S Corporations?

Burr & Forman on

Corporations, limited liability companies, and certain other business entities can make an election with the Internal Revenue Service to be taxed under Subchapter S of the Internal Revenue Code.  If such an election is made,...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

Rivkin Radler LLP on

“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Bradley Arant Boult Cummings LLP

ADOR Issues Guidance on New PTE Tax Election and Consequences of Decoupling from GILTI and IRC §118(b)(2)

At the urging of the Alabama Society of CPAs and other groups, the Alabama Department of Revenue (ADOR) recently issued preliminary guidance on (a) how the new pass-through entity (PTE) tax election interacts with the...more

Bradley Arant Boult Cummings LLP

TCJA Reform/CARES Act Bill Introduced in both House and Senate

On January 28, HB 170 and its Senate counterpart, SB 98, were prefiled with the Alabama Legislature and designated as three separate acts: (i) The Alabama Taxpayer Stimulus Freedom Act of 2021, (ii) The Alabama Business Tax...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

Seyfarth Shaw LLP on

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

Chambliss, Bahner & Stophel, P.C.

Five Important Tax Highlights from 2018

2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more

Burr & Forman

The New Section 199A 20% Profit Deduction for Pass-Through Businesses: A Case Study: Court Reporters

Burr & Forman on

Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Farrell Fritz, P.C.

The Proposed Sec. 199A Regs Are Still Here! Part Four

Farrell Fritz, P.C. on

This is the fourth[i] and final in a series of posts reviewing the recently proposed regulations (“PR”) under Sec. 199A of the Code. ...more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Farrell Fritz, P.C.

“The Proposed Sec. 199A Regs Are Here!”[*] Part One

Farrell Fritz, P.C. on

What follows is the first in a series of posts that will review the long-awaited proposed regulations under Sec. 199A of the Code – the “20% deduction” – which was enacted by the Tax Cuts and Jobs Act to benefit the...more

McGuireWoods LLP

IRS Proposes Regulations on New Section 199A Passthrough Deduction

McGuireWoods LLP on

On August 8, the Internal Revenue Service (IRS) and the Department of the Treasury released proposed regulations on new section 199A, the 20 percent deduction for qualified business income, added to the Internal Revenue Code...more

Partridge Snow & Hahn LLP

Proposed IRS Regulations Could Affect Your Ability to Take The New 20% Pass-Through Income Deduction

Overview - On Wednesday August 8, 2018, the IRS issued proposed regulations under Section 199A of the Income Tax Code (the “Proposed Regulations”) governing the new 20 percent deduction from income from certain...more

BakerHostetler

Opportunities and Limitations: Proposed Pass-Through Deduction Regulations Provide Clarity

BakerHostetler on

Since new Section 199A was enacted late last year as part of the Tax Cuts and Jobs Act (the TCJA, discussed in Congressional Conferees Approve Long-Awaited Tax Reform), business owners and tax professionals alike have been...more

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