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S-Corporation Income Taxes State Taxes

Rivkin Radler LLP

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

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Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...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

Baker Donelson

SALT Select Developments - February 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Blank Rome LLP

New York Appellate Court Rules in Favor of S Corporation Shareholder Entitlement to New York QEZE Tax Credits

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In a pair of decisions, a New York State appellate court has annulled decisions of the New York State Tax Appeals Tribunal that reduced certain tax credits available to the individual shareholders of their S corporation....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

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

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Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

Miles & Stockbridge P.C.

Maryland Updates Pass-Through Entity Election Requirements

The Maryland Comptroller’s Office issued a Tax Alert on April 11, 2023 addressing policy and procedural changes to pass-through entity (PTE) filings and payments. For tax years beginning after Dec. 31, 2022, PTEs are required...more

Harris Beach Murtha PLLC

Massachusetts Voters Vote "Yes" on Millionaire's Tax

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On November 8, Massachusetts voters voted “yes” to approve the imposition of a 4% surtax on Massachusetts taxpayers with income over $1 million. This so-called “Millionaire’s Tax” will be imposed on top of the state’s current...more

Rivkin Radler LLP

Leaving New York? Can You Prove It?

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“Summertime and the Living” Isn’t Easy- Summer in the New York Metro Area can be challenging. Some would say it sucks. It gets really hot. When it rains, it pours – no spritz here. The humidity is oppressive. Ironically, a...more

Venable LLP

Seller Beware - Court Rules That California Can Tax Gain from the Sale of Goodwill

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A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more

Greenberg Glusker LLP

California Provides Path to Deduct State Income Tax for Calculating Federal Tax [UPDATED]

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In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Herbert Smith Freehills Kramer

M&A Structuring Opportunities Utilizing State Level Pass-Through Entity Tax Regimes

State-level pass-through entity tax (PTET) regimes offer structuring opportunities in M&A transactions involving S corporation targets. PTET regimes have been adopted by a growing number of states as a workaround to the...more

Rivkin Radler LLP

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

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Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Bodman

Michigan Enacts Elective Flow-Through Entity Tax as “SALT Cap Workaround”

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On Monday, December 20, 2021, Michigan Governor Gretchen Whitmer signed House Bill (H.B.) 5376 into law.  H.B. 5376, also referred to as Michigan’s “SALT Cap Workaround,” amends the Michigan Income Tax Act to allow...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...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

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...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

Greenberg Glusker LLP

California Provides Path to Deduct State Income Tax for Calculating Federal Tax

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In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Bowditch & Dewey

Massachusetts Enacts Work Around to Federal $10,000 SALT Deduction Limitation

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On July 16, 2021, Governor Baker enacted legislation that allows (a) individual, trust and estate taxpayers who are partners in partnerships (or limited liability companies taxed as partnerships) and (b) individual, trust and...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

Kelley Drye & Warren LLP

New York State Enacts Elective Pass-through Entity Tax as a SALT Deduction Limitation Workaround

In April 2021, New York State enacted legislation providing for a new elective pass-through entity (PTE) tax on partnerships and Subchapter S corporations. The 2017 Tax Cuts and Jobs Act generally limits an individual’s...more

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

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The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

Blank Rome LLP

New York Governor Releases 2021-22 Executive Budget

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On January 19, 2021, New York State Governor Andrew M. Cuomo submitted his Executive Budget, applicable to the state’s fiscal year beginning April 1, 2021. The governor’s proposal, which will now be the subject of public...more

Fox Rothschild LLP

Partnerships And S Corporations Exempted From Limits On State And Local Tax Deduction

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The IRS intends to issue proposed regulations to permit a partnership or an S corporation to deduct specified income tax payments made to a domestic state or local jurisdiction. In Notice 2020-75, the IRS clarifies that...more

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