The Interaction of Section 461(l) and the Passive Activity Loss Rules
Section 461(l) of the Internal Revenue Code (“IRC” or “Code”) provides that a taxpayer other than a C corporation is not allowed to deduct “excess…
Income Tax
The “Taxpayer First Act” Becomes Law
President Trump signed the “Taxpayer First Act”, H.R. 3151, into law on July 1, 2019. The Taxpayer First Act may be one of the most…
Section 199A – The Decision to Aggregate
Under the 2017 Tax Cuts and Jobs Act, Congress enacted the new Section 199A 20% profit deduction for owners of pass-through businesses, and which include…
Cryptocurrency Tax Guidance Expected Soon
The Internal Revenue Service (“IRS”) will be releasing guidance on the tax treatment and reporting requirements of “virtual currencies” (i.e., cryptocurrencies) very soon, according to…
Senate Finance Committee Probing Conservation Easement Abuse
On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters…
The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners:
Assisted And Senior Living Facilities
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…
The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners:
Does It Apply To Rental Real Estate Activities?
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…
The New Section 199a 20% Profit Deduction For Pass-Thru Business Owners:
Employee Leasing May Help
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…
IRS Issues Final Regulations On New Section 199a 20% Profit Deduction For Pass-Thru Businesses, And Also Adds Additional Proposed Regulations And Further Guidance On New Deduction
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…
Conservation Easements: Building Envelopes Doom Donation
The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v.…