News & Analysis as of

Internal Revenue Service Tax Returns Limited Liability Company (LLC)

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.  
Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Allen Barron, Inc.

Important IRS and California Tax-Related Deadlines

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Don't stick your head in the sand and miss important business or personal tax deadlines...more

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more

Allen Barron, Inc.

It’s Time to Start Making Estimated Tax Payments Again California

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The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to...more

Holland & Knight LLP

IRS anuncia amnistía fiscal internacional nueva hasta el 30 de septiembre de 2022

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El servicio de impuestos internos de Estados Unidos (Internal Revenue Service o IRS) recientemente anunció una amnistía nueva que permite presentar ciertas declaraciones de 2019 y 2020 sin multa antes del 30 de septiembre de...more

Rivkin Radler LLP

Shared Appreciation Interest: Debtor-Creditor or Partners?

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When is a loan not a loan? When it’s something else – for example, equity. This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end. Debt- On one end of the...more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

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State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

Lowndes

As Tax Filing Deadline Approaches, Avoid This Trap for the Unwary If You Have an Open 1031 Exchange

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In the senior living area, a taxpayer that is selling a community may look to avoid recognizing gain on the sale by entering into a Section 1031 like-kind exchange with respect to the real estate. The tax rules generally...more

Miller Nash LLP

An Athlete's Guide to Philanthropy, Nonprofit Organizations, and Community Impact: Process and Pitfalls of Forming Nonprofit...

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As discussed in prior articles, there are several options for tax-incentivized giving, ranging from the informal and low-involvement to complex and highly involved structures. Many choose to adopt a more formal approach to...more

Rivkin Radler LLP

Gift Transfers: Not on the Congressional Agenda, But Still in the Crosshairs of the IRS

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Same old in D.C.- On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more

McDermott Will & Emery

Weekly IRS Roundup October 18 – October 22, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 18, 2021 – October 22, 2021... October 18, 2021: The IRS announced that beginning...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

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Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

Freeman Law

It’s Not Too Late!—Untimely S Elections

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In my practice, I have seen various issues related to a taxpayer’s S election. Corporations potentially jeopardize their S election by unknowingly creating a second class of stock through convertible debt. Corporations,...more

Farrell Fritz, P.C.

The Threat Of Higher Taxes, & The Sirens’ Song Of Tax-Saving Schemes

Farrell Fritz, P.C. on

What a Mess- A “perfect storm” may be defined as a critical state of affairs arising from the convergence of a number of negative factors, often after the unexpected introduction of some catalytic event. The situation...more

Burr & Forman

Section 199A – The Decision to Aggregate

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Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain...more

Lowndes

Now Is The Time To Review Your Tax Provisions

Lowndes on

As tax season is underway, one important deadline is coming that should not be overlooked. Tax law allows for partnership and LLC agreements to be amended retroactively to the first day of the prior year, provided the...more

Burr & Forman

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

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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

Bradley Arant Boult Cummings LLP

The New Partnership Audit Rules Are Here to Stay: It’s Time to Act - Construction and Procurement Law News, Q2 2018

The January 1, 2018 effective date of the new federal partnership audit rules quietly came and went, with many of our partnership and LLC clients and their advisers hoping that the rules were just a bad dream or would at...more

Chambliss, Bahner & Stophel, P.C.

New IRS Partnership/LLC Rules Require Your Immediate Action

New rules that change the way that partnership entities and limited liability companies are audited took effect on January 1, 2018. You may have received the legal update we sent on January 2, 2018....more

Foodman CPAs & Advisors

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

Smith Anderson

Draft North Carolina Tax Legislation Released

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On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

Jaburg Wilk

Partnership Audit Rules Have Changed Under New Tax Law

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Congress enacted the Bipartisan Budget Act of 2015 (“BBA”) under which existing partnership audit rules have been replaced. The new BBA audit rules are broad and complex and effective for partnership tax returns filed for tax...more

Bradley Arant Boult Cummings LLP

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

Carlton Fields

Playing With Fire: No Liability Coverage For Tax Preparers Who Took Deductions for Illegal Tax Shelters

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“Gimme Shelter” is one of the greatest of a lot of great Rolling Stones songs (made greater by Merry Clayton’s gut-wrenching contribution). And, of course, “Gimme Shelter” is a cliché often trotted out in discussions of tax...more

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