Congressional bills have been introduced that address the taxation of digital assets (e.g., Lummis-Gillibrand Responsible Financial Innovation Act and the Virtual Currency Tax Fairness Act). And, IRS has provided recent guidance on the topic. The bills, which are...
S corporations allow small business owners to enjoy the limited liability and other advantages afforded by corporations while, at the same time, obtaining the flow-through benefits of partnerships or sole proprietorships. However, the tax treatment of S corporations...
Online retailers had largely escaped state sales and use taxes before the U.S. Supreme Court decided South Dakota v. Wayfair, Inc. in 2018. Wayfair overruled the previous physical presence test which required sufficient nexus to impose a sales tax on electronic...
Managers of profit-sharing or retirement plans, IRAs, annuities, pensions, and other similar plans must be mindful of reporting obligations to the IRS. Learn more about how to complete, file, and amend IRS Form 1099-R (Distributions from Pensions, Annuities, Retirement...
Learn more about the complex subject of partnership allocations made in partnership agreements. The IRC refers to these allocations as a partner's "distributive share." I.R.C. § 704(a), (b) . Except for the basic flow-through nature of partnerships...
Property subject to depreciation and real property used in a trade or business is commonly referred to as I.R.C. Section 1231 property. Once you have concluded that property is I.R.C. Section 1231 property, your work is not done. This practice note assists with...
The IRS has released the Internal Revenue Service Data Book, 2022 which details its activities during fiscal year 2022 (October 1, 2021 – September 30, 2022). A release on the IRS website reveals that more than 262.8 million tax returns were processed and...
The purpose of a tax-free reorganization or restructuring is to acquire or dispose of assets of an entity without generating income and triggering a taxable event. An E Reorganization involves a single corporation that is undergoing a readjustment or reshuffling...
Many owners of sole proprietorships, partnerships, S corporations, and some trusts and estates may be eligible for a qualified business income (QBI) deduction—also called the Section 199A deduction. The deduction allows eligible taxpayers to deduct up to...
Brokerages have historically used Form 1099-B to report a taxpayer’s sale of securities. Since 2011, the IRS requires brokerage firms to report on Form 1099-B (or a substitute statement) the cost basis of securities sold or exchanged by the taxpayer and the...
Tax-exempt organizations, nonexempt charitable trusts, and I.R.C. Section 527 political organizations file Form 990 to provide the IRS with the information necessary to comply with I.R.C. Section 6033(e) , which imposes reporting and notice requirements on certain...
U.S. corporations must file a U.S. Corporation Income Tax Return (Form 1120) each taxable year, even if the entity isn’t reporting any taxable income (exceptions where a special return is required). One of the difficult aspects of filing the return is starting...
Learn more about the tax restrictions and limitations on related-party transactions that apply to partnerships and other flow-through entities. Because partnership tax items generally flow through directly to partners/LLC members, and do not remain with the entity...
The Internal Revenue Code imposes a variety of limitations and obstacles to individual taxpayers’ ability to deduct certain types of losses. There are generally three different types of losses covered in this practice note: casualty and theft; net operating;...
Section 1031 of the I.R.C. provides that no gain or loss will be recognized when real property held for productive use in a trade or business, or for investment, is exchanged for like-kind real property, also held for productive use in a trade or business or for...