When the Tax Cuts and Jobs Act[1] was introduced on November 2, 2017, perhaps the single most important issue on the minds of many closely held business owners was the future of the estate tax: was it going to be repealed as had been promised? A closely related question – and perhaps of equal
Some of the TC & JA’s Corporate Tax Changes
Our last three posts focused on those provisions of the Tax Cuts and Jobs Act[1] that apply specifically to pass-through entities, including partnerships and S corporations.
The 2017 Tax Act: Other “Pass-Through” Tax Provisions – Part II
The 2017 Tax Act: Other “Pass-Through” Tax Provisions – Part I
The 2017 Tax Act: Other “Pass-Through” Tax Provisions – Part II
Yesterday’s post examined various changes to the taxation of S corporations, partnerships, and their owners.
Today, we will focus on a number of partnership-specific issues that were addressed by the Act.
Profits Interests
A partnership may issue a profits (or “carried”) interest in the partnership to a service or management partner in exchange for their
The 2017 Tax Act: Other “Pass-Through” Tax Provisions – Part I
Our last post reviewed the “20% deduction” that may now be available to the owners of certain pass-through entities based upon their qualified business income; as we saw, there are many questions that remain unanswered.[1]
Today’s post is the first of two[2] this week in which we continue our consideration of those income tax provisions
The New Deduction for “Qualified Business Income”: Tax Simplification Gone Awry?*
In the weeks preceding the introduction of the bill that was just enacted as the Tax Cuts and Jobs Act (the “Act”), my colleagues teased me, “Lou, what are you going to do when Congress simplifies the Code?”
“Simplify?” I responded as I reached for the Merriam-Webster’s Dictionary that I have used since 1980 –
Revoking S Corp. Status: A Fraudulent Conveyance?
Worlds Collide?
I like to tell my partners that there are Codes (upper case “C”), and there are codes (lower case “c”). The former include the Ten Commandments, the Code of Hammurabi, the Code of Justinian, and the Internal Revenue Code. The latter include the Pirate’s Code – which, as Captain Barbossa tells us in
Information Reporting for the Foreign-Owned Not-So-Disregarded Disregarded Entity
Ah, December
As we near the end of the taxable year ending December 31, 2017, the thoughts of most people turn to holidays and family gatherings, feasting and celebrations, and reflecting, perhaps, on another year gone-by.
Not so for tax professionals.
Instead of “visions of sugar plums” dancing in their heads, these poor folk dream
Minority Owner Or No Owner at All?
Old Dog, New Tricks?
It’s a concern for every new investor in a closely held business: will the founding owners continue to operate the business as they always have, or will they recognize that they now have new co-owners to whom they owe a fiduciary duty, and on whom they made be dependent for funding
S Corp. Shareholder to Tax Court: “Here’s Why I Deserve These Loss Deductions”
A post earlier this year considered the basis-limitation that restricts the ability of S corporation shareholders to deduct their pro rata share of the corporation’s losses. It was observed that, over the years, shareholders have employed many different approaches and arguments to increase the basis for their shares of stock or for the corporation’s indebtedness,
LLC-to-Partnership Conversion: There’s More to it Than Meets the Eye
Some Days Are Stones[1]
It’s not always easy to find a topic about which to write a weekly blog post. I usually look for a ruling or decision that illustrates one of the recurring themes of the tax law, and then develop a lesson or message around it. Sometimes I’ll use a project on