News & Analysis as of

Partnerships Pass-Through Entities Tax Reform

Nelson Mullins Riley & Scarborough LLP

QSBS Gets a Makeover: Key Changes Under the OBBBA

The One Big Beautiful Bill Act (OBBBA) made the following changes to qualified small business stock (QSBS): The holding period is now graduated for stock acquired after July 4, 2025....more

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

Jackson Walker on

In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part IV – The Qualified Business Income Deduction / Code Section...

Foster Garvey PC on

In this fourth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), Steve Nofziger and I discuss a provision of the Act that impacts pass-through business entities and their owners, Code Section...more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

Ropes & Gray LLP on

The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Proskauer - Tax Talks

The One Big Beautiful Bill: SALT Deduction Workarounds Under Fire

Proskauer - Tax Talks on

On May 12, 2025, House Republicans unveiled a comprehensive 389-page package of tax provisions, setting the stage for a significant tax bill to be debated in the coming weeks. Dubbed the “One Big Beautiful Bill,” this...more

DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Increased Funding Would Support IRS Drive To Audit More Partnerships and Wealthy Individuals

More — and more rigorous — IRS examinations are coming. The Biden administration is committed to closing the “tax gap” (the difference between taxes owed and taxes actually paid on time). Increased enforcement efforts are...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

Williams Mullen

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

Williams Mullen on

As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...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

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

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Tax Reform Update: Early Impact and Trends

Six months after the most significant U.S. tax reform legislation since 1986 was signed into law, it is still too early to predict the long-term effects. A number of technical uncertainties remain, and taxpayers are...more

Verrill

Lawyers on Tap: Tap Tips for Entity Formation and Taxation

Verrill on

In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more

Lowndes

Time to Reconsider Your Choice of Entity?

Lowndes on

One of the most publicized changes made by last year’s Tax Cut and Jobs Act was a reduction in income tax rates for corporations and individuals. The maximum corporate tax rate has been permanently reduced from 35% to 21%,...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Schwabe, Williamson & Wyatt PC

CPA Shoptalk: 8 Takeaways

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Vedder Price

Tax Reform: Impact on Private Equity and M&A

Vedder Price on

On December 22, 2017, new tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Act”) was signed into law. The Act represents a major overhaul of the U.S. federal tax system and includes many new provisions,...more

Burr & Forman

The New 20% Pass-Through Deduction: Can Real Estate Owners Claim It?

Burr & Forman on

The new 20% deduction for “pass-through” business owners under the Tax Cuts and Jobs Act is raising many questions from owners of real estate-related businesses. Can these owners qualify for this important deduction, and...more

Clark Hill PLC

Choice of Entity: Are Partnerships Still More Tax Efficient After Tax Reform?

Clark Hill PLC on

Prior to tax reform, tax considerations tipped the scale heavily in favor of operating a business through a partnership or other pass-through entity rather than a corporation. Now that the corporate income tax rate has been...more

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

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

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Healthcare Industry?

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

Orrick, Herrington & Sutcliffe LLP

Energy Taxation: Impact Of The Tax Cuts And Jobs Act

Congress has passed the tax reform bill, known as the "Tax Cuts and Jobs Act", and President Trump signed it into law on December 22, 2017. The Act contains wide-ranging changes to the tax law that affect many industries. ...more

Farrell Fritz, P.C.

The 2017 Tax Act: Other “Pass-Through” Tax Provisions – Part II

Farrell Fritz, P.C. on

Yesterday’s post examined various changes to the taxation of S corporations, partnerships, and their owners. Today, we will focus on a number of partnership-specific issues that were addressed by the Act. Profits...more

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