The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a $10,000 cap on the federal deduction for state and local taxes for tax years 2018-2025. While corporations are not subject to the cap, business owners who pay state and local income tax on pass-through income are subject to the cap.
On November 9, 2019 the IRS released Notice 2020-75 indicating it would issue regulations to clarify that state and local taxes paid by a partnership or corporation would be deductible by the partnership or S corporation when they compute their pass-through income. This guidance paves the way for states to enact ...
In the late hours of March 25, 2020, the United States Senate met to vote on a third “Coronavirus” bill to provide relief to the American people. The Senate ultimately passed H.R. 748—the Coronavirus Aid, Relief, and Economic Security Act or “CARES Act.” Two days later, the House followed suit and sent the bill the President for his approval. The Act contains many stimulus provisions, even some that affect recently-amended Internal Revenue Code (“Code”) sections. This post covers an important amendment to Section 172, which governs the use of “net operating ...
Congress enacted the Opportunity Zone (“OZ”) investment incentives in late 2017 as part of the Tax Cuts and Jobs Act. Since then many investors, fund managers, and community development professionals have devoted significant time and resources to locating and underwriting investment opportunities. The legislation left many unanswered questions – largely limiting investments to obvious qualifying businesses. The first set of proposed regulations, released October 29, 2018, provided further guidance but not enough to answer many remaining questions.
The 50% Gross ...
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 trusts. Section 199A is intended to provide a deduction to owners of these pass-through business entities who do not otherwise benefit from the new 21% flat tax Congress has given to corporations under the new tax law. While Section 199A is intended to benefit these generally smaller types of business entities and their owners, the new tax law is riddled with ...
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 trusts. Section 199A is intended to provide a deduction to owners of these pass-through business entities who do not otherwise benefit from the new 21% flat tax Congress has given to corporations under the new tax law. While Section 199A is intended to benefit these generally smaller types of business entities and their owners, the new tax law is riddled with ...
On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly anticipated because filing season for the first year of the new tax law, 2018 generally, is now upon us. The final regulations were issued after public comments were received in response to proposed Section 199A regulations issued last August. The IRS, in IR-2019-04 (January 18, 2019), also released a new set of additional proposed resolutions under Section 199A ...