News & Analysis as of

Tax Reform Tax Planning Partnerships

Cadwalader, Wickersham & Taft LLP

Wyden’s Partnership Tax Bills: A Mouthful and Then Some

On June 17, 2025, Senator Ron Wyden introduced two extensive partnership tax reform bills in the Senate (collectively, the “Bills,” and available here and here).  The Bills expanded upon and incorporated many of Wyden’s 2021...more

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

Morris, Manning & Martin, LLP

The One Big Beautiful Bill: What Every Commercial Real Estate Investor Needs to Know

The commercial real estate landscape is undergoing one of its most significant policy overhauls in years. The recently enacted “One Big Beautiful Bill” brings sweeping changes to tax incentives, financing rules, and...more

McDermott Will & Schulte

Key One Big Beautiful Bill Act implications for family offices and high-net-worth investors

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA), the most significant US tax overhaul since the 2017 Tax Cuts and Jobs Act (TCJA). The OBBBA includes critical changes impacting family offices,...more

Rivkin Radler LLP

Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?

Rivkin Radler LLP on

The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

Rivkin Radler LLP on

Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more

Proskauer - Tax Talks

The Biden Administration Proposes Changes to the Taxation of Partnerships

Proskauer - Tax Talks on

On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more

Cadwalader, Wickersham & Taft LLP

Proposed Regs Affect PFIC Elections

On January 25, 2022, the IRS and Treasury proposed regulations that would treat U.S. partners, instead of their partnerships, as PFIC shareholders for making qualified electing fund, mark-to-market, or purging elections,...more

Bodman

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

Bodman on

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

Stinson LLP

NIIT Expansion Under Proposed Build Back Better Act Includes Subtle Tax Increase on Sales of Private Businesses

Stinson LLP on

In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more

McDermott Will & Schulte

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

McDermott Will & Schulte on

Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...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 Rose LLP

UK Tax Round Up - January 2021

Proskauer Rose LLP on

UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more

McDermott Will & Schulte

[Webinar] 2020 Family Office Tax Roundtable - October 21st, 11:00 am - 2:00 pm PDT

McDermott Will & Schulte on

McDermott Will & Emery’s Family Office Tax Roundtable provides participants with an interactive virtual program focused on select income and transfer tax considerations for family enterprises. Attendees will hear...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...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

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

Vedder Price on

New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

Skadden, Arps, Slate, Meagher & Flom LLP

Impact of US Tax Reform on Cross-Border Estate Planning

The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...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

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part III: IRC § 708 and the Partnership Termination Rules Have Changed

Foster Garvey PC on

BACKGROUND/PRIOR LAW - PartnershipUnder IRC § 708(a), a partnership is considered as a continuing entity for income tax purposes unless it is terminated. Given the proliferation of state law entities taxed as partnerships...more

Mayer Brown

What Is the Impact of Tax Reform on US Wind Tax Equity Deals?

Mayer Brown on

A Word About Wind has published our article What Is the Impact of Tax Reform on US Wind Tax Equity Deals? in its blog (subscription required) and newsletter. ...more

22 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide