Real property transactions involving easements granted in the name of conservation can yield tax deduction benefits to the grantor. While the validity of charitable contributions in this area is subject to scrutiny and deduction claims are prone to challenge by...
As the population ages and more taxpayers live on fixed incomes, both federal and state governments face challenges in determining the appropriate level of taxation for retirees. For federal income tax purposes, retirement income is generally fully includable in...
Explore the taxation of business profits under U.S. international tax treaties, focusing on the critical role these treaties play in preventing double taxation and clarifying cross-border tax obligations. This practice note explores the concept of permanent establishment...
In 2025, navigating the IRS's tax collection process is more critical than ever, as changing tax laws and economic shifts demand vigilance from both individuals and businesses. The IRS, armed with a formidable team of Revenue and Appeals Officers, is tasked...
Executive Order 14210 issued by the Trump Administration calls for a "critical transformation of the Federal bureaucracy," which provides, among other things, submission of a plan by the Director of the Office of Management and Budget (OMB) to reduce...
A limited liability company (LLC) can be taxed as an S corporation, but an S corporation is not always a good choice. Learn the tax options available to LLCs and the advantages and disadvantages of electing to be taxed as an S corporation. When evaluating the procedures...
The U.S. branch profits tax (BPT) is a critical component of the federal tax system, ensuring foreign corporations with U.S. branches face a tax burden similar to U.S.-incorporated subsidiaries. Imposed at a 30% rate on the "dividend equivalent amount,"...
Virtually every state has some type of franchise tax or fee that is imposed on domestic and/or foreign corporations as part of the cost of doing business in the state. The measure of franchise taxes varies from state to state. While some franchise taxes are measured...
A business entity that is treated as a disregarded entity for tax purposes is generally ignored for U.S. federal income tax purposes even though it is a separate legal entity for state law purposes. While disregarded entities offer significant advantages to the...
For tax practitioners, understanding tariffs is one of the keys to unlocking the complexities of international trade. Tariffs not only shape the cost structure of imported goods but also ripple through pricing strategies, supply chain decisions, and overall business...
The Creating Helpful Incentives to Produce Semiconductors Act of 2022 (CHIPS Act), Pub. L. No. 117-167, § 107, was signed into law by President Biden on August 9, 2022. With the goal of incentivizing semiconductors and semiconductor manufacturing within the...
As we enter 2025, the renewal of the Tax Cuts and Jobs Act of 2017 (TCJA) is front and center for Republicans, who hold majorities in both chambers of Congress. Despite internal divisions and procedural hurdles, Senate Majority Leader John Thune aims to use budget...
The allocations that partners establish in their partnership agreement determine each partner's distributive share. A partner’s distributive share is that fraction of a partnership's items of income, gain, loss, deduction, and credit that the partnership...
As we step into the new year, it's a great time to reflect on any changes in partnership interests that took place in 2024. The sale or exchange of a partnership interest is only one way in which partnership interests can change. For example, if a partner,...
With Republican control of the White House, the Senate, and the House of Representatives, President-elect Donald J. Trump is expected to support a wide range of policies including raising tariffs and lowering taxes. Possibilities include $2 trillion in tax cuts...