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
The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act. The IRS Large Business and International ("LB&I")...more
The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more
The IRS recently (September 2019) published Rev. Proc. 2019-38, finalizing the proposed safe harbor requirements under which a rental real estate enterprise (RREE) will qualify as a trade or business for purposes of Internal...more
On September 24, the IRS issued Revenue Procedure 2019-38, clarifying rental real estate owners’ eligibility for the highly anticipated tax break under section 199A of the Internal Revenue Code. Section 199A Deduction...more
Section 199A introduced a 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. Whether rental activity rises to the level of a trade or business can often be a...more
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
It’s Not Easy- The owners of many closely held businesses recently filed federal income tax returns on which they claimed, for the first time, the deduction based on “qualified business income” under Section 199A of the...more
For a lot of us, the first income tax year under the Tax Cuts and Jobs Act of 2017 is in the rearview mirror. Now is the time for you commercial real estate owners and investors to sit down and figure out how you utilized...more
Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. Many senior living communities hold their real property in a separate entity,...more
Comments are due on April 9, 2019 with respect to the recent proposed regulations regarding eligibility of qualified REIT dividends for the qualified business income deduction under Code Section 199A. On January 18, 2019...more
On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more
Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more
Treasury finalizes rules for key component of tax reform for pass-through trades and businesses. Key Points: ..The deduction of up to 20% of pass-through trade or business income effectively may reduce the top marginal...more
One of the most dramatic changes made by the Tax Cuts and Jobs Act enacted in December 2017 was the creation of a new 20% qualified business income ("QBI") deduction under new Section 199A of the Internal Revenue Code (the...more
Under the 2017 Tax Cuts and Jobs Act, Congress enacted a 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
The Internal Revenue Code (“IRC”) Section 199A Qualified Business Income Deduction (“QBI Deduction”) generally provides a 20% deduction (or reduction) of a taxpayer’s qualified net business income received from a pass-through...more
Do you have a tech business that you operate as a pass-through entity? If so, Section 199A of the recent tax reform legislation may apply to you or your business. This provision introduces a 20% deduction for qualified...more
On January 18th, the U.S. Department of Treasury and the Internal Revenue Service issued a package of guidance relating to the 20-percent qualified business income deduction for non-corporate taxpayers under Section 199A of...more
Section 199A introduced a new 20% deduction for qualified business income. To qualify for the deduction, income must be from a trade or business. ...more
When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings. Hopefully, their...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 28 – February 1, 2019. January 28, 2019: The IRS issued Revenue Ruling 2019-04,...more
Along with the recent issuance of regulations under section 199A of the Internal Revenue Code (“I.R.C.”), the Internal Revenue Service (“the Service”) also published a revenue procedure setting forth a safe harbor under which...more
From its inception, Section 199A made it fairly clear that the deduction for qualified business income (“QBI”) would not apply to all income in respect of pass-through businesses. Aside from limitations dependent on the...more