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 ...
There is a long list of reforms that the Trump administration intends to tackle and one of the items on the list is tax reform. Although there are multiple proposals by various players and significant variations among the proposals, the three primary goals of reform appear to be a reduction in income tax rates for both corporations and individuals, simplification, and some adjustment of the international tax regime. As is the case with all things political, the outcome is difficult to predict with any certainty and perhaps all or none of these objectives will be achieved. This ...