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Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

Rivkin Radler LLP

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

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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

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Williams Mullen

Newly Released Final Regulations on Partnership Basis-Shifting Transactions

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On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...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

Rivkin Radler LLP

Expiring Federal Transfer Tax Benefits – Nothing is Certain or Lasts Forever

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Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...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

Freeman Law

The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with...

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The 2022 Global Penalty Relief | Notice 2022-36 | Who qualifies and who does not? Relevant Implications for taxpayers with international assets/accounts. The IRS has just released Notice 2022-36 which provides an...more

Lowndes

As Tax Filing Deadline Approaches, Avoid This Trap for the Unwary If You Have an Open 1031 Exchange

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In the senior living area, a taxpayer that is selling a community may look to avoid recognizing gain on the sale by entering into a Section 1031 like-kind exchange with respect to the real estate. The tax rules generally...more

Bowditch & Dewey

IRS Discusses New IRS Return Examination Campaigns

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In remarks at the NYU Tax Controversy Forum in June, the IRS discussed two new IRS return examination campaigns. Ms. Tamera Ripperda, the commissioner of the Tax Exempt and Government Entities (TEGE) Division who previously...more

Ballard Spahr LLP

IRS Allows Partnerships To File Amended Returns To Claim Immediate Expensing For Qualified Improvement Property

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The IRS issued Rev. Proc. 2020-23 allowing partnerships subject to the BBA partnership audit rules to file amended returns to take advantage of retroactive tax benefits in the CARES Act, including the qualified improvement...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...more

McDermott Will & Schulte

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Schulte

Weekly IRS Roundup September 30 – October 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Lowndes

Reminder: Partnership and S Corporation Returns Due Today

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As I previously discussed, the federal tax due date for partnership and corporate tax returns changed a few years ago. ...more

Troutman Pepper Locke

Do You Know Who Your Partnership Representative Is? - Tax Update Volume 2019, Issue 1

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The new partnership audit rules apply to tax years beginning in 2018. While the new rules eliminate the need for a tax matters partner, that role is replaced with a new role called the partnership representative (PR). ...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

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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

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

Butler Snow LLP

Congress Fixes “Grain Glitch” Error in 199A

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On March 23, the Consolidated Appropriations Act (the “Appropriations Act”) was signed into law by President Trump. Included in the Appropriations Act were certain tax law provisions, including technical corrections to the...more

Butler Snow LLP

Partnership Audit Rules Clarified by the Consolidated Appropriations Act

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Technical corrections to the partnership audit rules were included in the 2018 Consolidated Appropriations Act signed by President Trump on March 23rd (the “Appropriations Act”). ...more

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