The Tax Cuts and Jobs Act[i] has been called a lot of things by a lot of different people.[ii] Certain provisions of the Act, however, coupled with recently proposed regulations thereunder,[iii] may result in its being known as the legislation that caused many individuals to willingly metamorphose – at least for some
P.L. 115-97
Choice of Entity? I Choose A . . . No, I Meant B . . . Wait, Can I Try Again?
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
Choice of Entity
The owners of a closely held business will confront many difficult decisions during the life of the business. Among the earliest of these decisions – and one with which the business may have to contend for many years to come[i] – is the so-called “choice of entity”: in what legal form…
A Closely Held Qualified Opportunity Fund? It’s Possible, But It’s Not Easy
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
Committed to a Zone
Last week’s post[i] considered how the newly-enacted qualified opportunity zone (“QOZ”) rules seek to encourage investment and stimulate economic growth in certain distressed communities by providing various federal income tax benefits to taxpayers who invest in businesses that operate within these zones.[ii] After describing these tax incentives, the post…
Sale of a Business and Qualified Opportunity Funds: Deferral, Exclusion, and . . . Risk?
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
A lot has been written about the tax benefits of investing in a Qualified Opportunity Fund. Some have suggested that the gain from the sale of a closely held business may be invested in such a fund in order to defer the recognition of this gain and to shelter some of the appreciation thereon.
In…
It’s a Business . . . No, It’s a Charity . . . Wait – It’s a Charity That Is Treated Like a Business?
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
The Business-Charity Connection
As our readers know, this blog is dedicated to addressing the tax-related business and succession planning issues that are most often encountered by the owners of a closely held business. Occasionally, however, we have crossed over into the space occupied by tax-exempt charitable organizations inasmuch as such an exempt organization (“EO”) may…
Trusts and the Section 199A Deduction
By Farrell Fritz P.C. on
Posted in Federal Tax Issues
If there was one part of the Tax Cuts and Jobs Act (“TCJA”) that estate planners were especially pleased to see, it was the increase in the basic exclusion amount from $5.49 million, in 2017, to $11.18 million for gifts made, and decedents dying, in 2018.[i] However, many estate planners failed to appreciate the…