News & Analysis as of

Tax Returns Tax Cuts and Jobs Act

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

Morgan Lewis

New Section 174A Restores Domestic R&E Deductibility, but Other Changes Bring Mixed Results

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President Donald Trump signed into law the One Big Beautiful Bill Act on July 4, 2025. Among many other provisions, this bill permits taxpayers to deduct domestic research and experimentation (R&E) expenditures under new...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part I – The SALT Deduction

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On July 1, 2025, the One Big Beautiful Bill Act, H.R.1 – 199th Congress (2025-2026) (the “Act”) was passed in the U.S. Senate (“Senate”). On July 3, 2025, it was passed in the U.S. House of Representatives (“House”) and...more

Foster Garvey PC

The State and Local Tax Deduction Is in Peril – The Cavalry Does Not Appear to Be on Its Way to Rescue It

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Prior to the Tax Cuts and Jobs Act (“TCJA”), there was no direct limitation on an individual taxpayer’s deduction of his or her state and local taxes (“SALT”) on the federal individual income tax return. Of course, for...more

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

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As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

Allen Barron, Inc.

The Sunset of the TCJA – Tax Cuts and Jobs Act of 2017 – Is Scheduled for the End of 2025

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The sunset of the TCJA – the Tax Cuts and Jobs Act of 2017, is currently scheduled for the end of 2025.  The TCJA contributed substantial changes to the US tax code that have benefited many US taxpayers.  How should a US...more

Eversheds Sutherland (US) LLP

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

Patterson Belknap Webb & Tyler LLP

Protective Refund Claims in Light of Pending Moore v. United States Decision

Taxpayers, including some of the firm’s current and former clients, may be affected by the outcome of the Supreme Court case Moore v. United States, which will address the constitutionality of the Section 965 “Transition...more

Bradley Arant Boult Cummings LLP

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more

Eversheds Sutherland (US) LLP

Government cleans up List of Automatic Changes in Rev. Proc. 2023-24

On June 15, 2023, the IRS released Rev. Proc. 2023-24, List of Automatic Changes, which provides an update to the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures....more

McDermott Will & Schulte

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Moritt Hock & Hamroff LLP

IRS Grants Major Extension To Make “Portability” Election For Estates Not Required To File Estate Tax Returns From 2017 To Present

IRS Alert: The Internal Revenue Service (“IRS”) recently issued Revenue Procedure 2022-32 which provided surviving spouses extended relief to make “portability” elections without the need for the issuance of a private letter...more

Freeman Law

Section 965 Tax Installment Payments Are Not Guaranteed

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The Section 965 transition tax. Taxpayers with international earnings are still grappling with their reporting and payment obligations under the “deemed repatriation” tax after its enactment by the Tax Cuts and Jobs Act of...more

Bradley Arant Boult Cummings LLP

ADOR Grants Extension to Make PTE Tax Election for 2021 Tax Year

Readers may recall that the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) last year as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Jones Day

IRS Targeting Noncompliant Qualified Opportunity Funds and Their Investors

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On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

Freeman Law

Recent Tax Court Case and Theft-Loss Deductions

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A recent Tax Court case dealt with a familiar topic: Theft losses. I.R.C. section 165 has historically allowed taxpayers to deduct three types of losses: those incurred in a trade or business, those incurred in a transaction...more

McDermott Will & Schulte

Weekly IRS Roundup May 10 – May 14, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 10, 2021 – May 14, 2021... May 10, 2021: The IRS issued Revenue Procedure 2021-25,...more

McDermott Will & Schulte

Weekly IRS Roundup February 22 – February 26, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 22, 2021 – February 26, 2021... February 25, 2021: The IRS issued an alert warning...more

Bowditch & Dewey

Are Your Unreimbursed Partner’s Expenses Deductible?

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Since the Tax Cuts and Job Act of 2017 (TCJA) was passed, a little-known deduction for unreimbursed partner’s expenses (UPE) has taken on more significance. Partner’s in partnership and members of an LLC often incur...more

Gould + Ratner LLP

New Stimulus Allows Faster Depreciation of Certain Residential Rental Property Held by Electing Real Property Trades or Businesses

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The stimulus package passed last month may help certain Electing Real Property Businesses by including a provision that allows a shorter depreciation period for residential rental property acquired prior to January 1, 2018. ...more

Flaster Greenberg PC

How to Make Filing Your 2020 Returns Less Taxing

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Unquestionably, 2020 was a year full of unforeseen challenges. As much as we may want to put last year completely behind us, we need to file our 2020 tax returns before completely letting go. Although we speak about the...more

BakerHostetler

Did the IRS Bless the Passthrough Entity Workaround to the $10K SALT Cap?

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For three years, states and taxpayers have been looking for novel ways to get around the federal TCJA's $10,000 cap on deducting state and local taxes. The IRS just released Notice 2020-75, which appears to bless states'...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

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