Legal Updates & Commentary for Tax & Estate Planning
You may recall how clear it became, as the bill that would become the Tax Cuts and Jobs Act (“TCJA”)[i] moved through Congress in late 2017, that C corporations were about to realize a number of tax benefits, the most significant being the introduction of a flat federal corporate income tax rate…
As we approach the presidential convention season,[i] and the election campaign that will follow, the thoughts of many business owners have turned to the federal estate tax, and for good reason.[ii]
After the Great Recession of 2007-2009,[iii] the economy enjoyed a period of sustained growth of approximately 11…
As a general rule, a taxpayer’s exchange of one property for another property is treated as a taxable event; the gain realized by the taxpayer – meaning the amount by which the fair market value of the property received by the taxpayer[i] exceeds the taxpayer’s adjusted basis (unrecovered investment) in the…
The Internal Revenue Code is one of the tools employed by Congress to encourage certain behaviors that it has determined are in society’s long-term best interest and, therefore, worthy of the public’s financial support. Among the socially-desirable behaviors to which the Code is applied, perhaps the best-known is that of…
Letters, acronyms, initialisms[i] – they seem to slip into every post these days.
It has always been a goal of U.S. tax policy to ensure that taxable income sourced in the U.S. does not escape the federal income tax.
In general, this income and the scenarios in which it arises are easily identifiable. However,…
Over the last several weeks, we have explored various aspects of the choice of entity dilemma that confronts the owners of many closely held businesses, and we have considered how the Tax Cuts and Jobs Act[i] may influence their decision.
In the process, you may have realized that one form of…
Following the enactment of the Tax Cuts and Jobs Act,[i] tax advisers were inundated with inquiries from the individual owners of closely held businesses regarding a broad spectrum of topics.[ii] Perhaps the most often repeated question concerned the form of legal entity through which such a business should be operated.…
I recently recalled a client that was referred to us a few years back, shortly before it was acquired by a larger company. The client was closely held by U.S. individuals and by an S corporation, and was organized as a Delaware LLC that was treated as a partnership for U.S.…
Yesterday, in Part I, we reviewed the like-kind exchange rules. https://www.taxlawforchb.com/2019/04/deferring-real-property-gain-like-kind-exchange-or-opportunity-fund-part-i/
Now we turn to the new kid on the block.
The Act added Section 1400Z-2 to the Code, which allows a taxpayer to elect to temporarily defer the recognition of gain from the disposition of property which is reinvested in a…
Among the business transactions on which the Tax Cuts and Jobs Act[i] has had, and will continue to have, a significant impact is the disposition of a taxpayer’s interest in real property, whether held directly or through a business entity.
That is not to say that the Act amended an existing Code…
