News & Analysis as of

Pass-Through Entities Federal Taxes

Foster Garvey PC

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

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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

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Cooley LLP

Proposed Federal Tax Legislation Would Effect Three Key Changes to State and Local Tax Deductibility Limits

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On May 22, the House of Representatives passed proposed tax legislation titled, “The One, Big, Beautiful Bill” (TOBBB), which will now be debated in the Senate. Among other proposals, if enacted into law, TOBBB would make...more

Rivkin Radler LLP

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

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Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Rivkin Radler LLP

Some Observations On Recent Conversions of Partnerships to “C” Corporations

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Decisions- It is often the case that the optimal form of legal entity through which a business should operate, at least for income tax purposes, will depend in part upon the stage of its life cycle in which the business...more

Polsinelli

Beware, the IRS is Coming: More IRS Audits to Focus on High-Net Worth Individuals and Passthrough Entities

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After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Arkansas's Answer to the SALT Cap for Business Owners: The Arkansas Pass-Through Entity Tax Act

The Tax Cuts and Jobs Act of 2017 (The “TCJA”) imposes a $10,000 cap on the amount an individual may deduct for federal tax purposes for the payment of state and local income, property and sales taxes (referred to as “SALT”)....more

Harris Beach Murtha PLLC

Massachusetts Enacts Pass-Through Entity Tax

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One of the most controversial individual income tax changes enacted under the Tax Cuts and Jobs Act of 2017 is the $10,000 cap on the deduction for state and local income and property taxes (“SALT”) for federal income tax...more

Kilpatrick

4 Key Takeaways | Mid-Year Tax Update

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On June 22, 2021, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the...more

Bowditch & Dewey

Massachusetts Legislature Passes Legislation Enacting Work Around to Federal $10,000 SALT Deduction Limitation, but Governor Baker...

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On July 16, 2021, Governor Baker approved a $47.6 billion fiscal 2022 budget, but sent back a provision the Massachusetts Legislature passed creating a workaround for the federal cap on the state and local tax deduction. ...more

Gould + Ratner LLP

Pending Changes to Illinois Tax Laws Include SALT Workaround

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Illinois lawmakers have approved legislation that is both good news and bad news for Illinois taxpayers. The good news is that, if approved by Gov. Pritzker, Illinois taxpayers will be able to take advantage of a workaround...more

Herbert Smith Freehills Kramer

Flow-through Tax Status as a Property Right? The Case of Schroeder Brothers Farms

A recent case from the Western District of Wisconsin, In re Schroeder Brothers Farms of Camp Douglas LLP, may raise a new issue for the bankruptcy treatment of tax attributes in flow-through entities. The court in Schroeder...more

Fenwick & West LLP

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

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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

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

Burr & Forman

New IRS Proposed 199A Regulations Provide Guidance on 20% Profit Pass-Through Deduction

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On August 8th, the IRS released its much-awaited Proposed Regulations on the new Section 199A 20% profit deduction for pass-through businesses. The new deduction applies to essentially all types of businesses other than C...more

Morrison & Foerster LLP

Tax Reform: Key Considerations for Real Estate Investment Trusts

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the "Act") into law. Although the individual and collective impact of the Act may not be evident for some time, the Act is generally viewed by the real...more

Holland & Knight LLP

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 4

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The House of Representatives on Nov. 16, 2017, voted on and passed their tax reform bill, along party lines (227-205). Passage was expected in the House, where the GOP hold a significant enough majority needed to move the...more

Holland & Knight LLP

Private Equity and Other Carried Interest Funds – Federal Tax Policy Tip Sheet: Issue 2

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House GOP leaders on Thursday, Nov. 2, released their anticipated tax-reform proposal. Entitled the "Tax Cuts and Jobs Act," the House Bill includes several proposed changes to the corporate and individual tax system....more

Cooley LLP

S Corporations: The Basics

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An S Corporation is the same as any other corporation except for the manner in which it is taxed. S Corporations generally do not pay federal income tax but pass the tax liability for their profits through to their...more

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