Use the Practical Guidance State Law Comparison Tool (SLCT) to answer questions, state-by-state, for tax matters regarding withholding, business taxes, and treatment of independent contractors. We’ve recently added a “Local Taxes” topic to explore...
There are circumstances in which the IRS will consider a taxpayer’s economic hardship in determining whether the taxpayer can meet its tax burden (typically because of a deficiency assessment). This practice note discusses the process and procedures by which...
Running the cost/benefit analysis of buying electric vehicles (EVs) can be a challenge. Plus, moving from combustion engines to EVs or other clean vehicles may take some planning. Will the credits offered by the Inflation Reduction Act result in a consumer buying...
Now on Practical Guidance! Put down the books and listen to our Practical Guidance podcasts and curated Law360 podcasts, conveniently available in one place. We’ve organized our podcasts by practice areas, Tax included! LISTEN NOW » Related Content...
Practical Guidance now has podcasts and curated Law360 podcasts. This particular podcast is part of a series concerning cannabis, including how the Internal Revenue Code treats as nondeductible (under I.R.C. Section 280E ) most expenses related to a cannabis business...
Transactions involving the disposition of partnership property or partnership interests can trigger rules that limit business interest expense deductions. Section 163(j) of the Internal Revenue Code generally limits the deductibility of a partnership’s business...
In the last few years, the Organisation for Economic Co-operation and Development (OECD) has discussed a more permanent and effective plan to change tax rules for large companies and limit tax avoidance planning by multinationals, adopting a two-pillar solution...
Part of the IRS’s 2022-2023 Priority Guidance Plan includes providing guidance under the provisions of the Inflation Reduction Act ( Pub. L. No. 117-169 ) regarding computation and reporting of the excise tax under I.R.C. § 4501 on the repurchase of...
With an $80 billion increase in funding for IRS enforcement, IRS is expected to expand its existing programs that examine large, complex partnerships, focusing on issues such as partnership transactions, partners' tax basis, and limited partners' self-employment...
Family limited partnerships (FLP) and family limited liability companies (FLLC) offer unique tax issues. If your client is contemplating creating an FLP or FLLC, this practice note will assist you in reviewing the family partnership rules, the role of children...
The Bipartisan Budget Act of 2015 (BBA) ( Pub. L. No. 114-74 ) changed the audit and collection procedures for partnerships, effective for tax years beginning after December 31, 2017. Congress intended that the BBA would simplify partnership audit procedures (at...
Not again! Treasury has issued proposed regulations concerning the foreign tax credit (again) that address the cost recovery, attribution for royalty payment withholding tax, and defining a reattribution asset for purposes of allocating and apportioning foreign...
Private equity investments are a particularly important subject to tax attorneys involved in entity formations, equity issuances, and M&A transactions. This practice note discusses U.S. federal income tax considerations that arise in a preferred equity investment...
The Inflation Reduction Act ( Pub. L. No. 117-169 ), as enacted on August 16, 2022, extended, expanded and renewed alternative fuel vehicle refueling property (AFVRP) tax credits that apply to electric vehicle charging stations, liquefied natural gas, compressed...
It’s important to understand the tax benefits and drawbacks of basic corporate merger structures. The form of the merger is important as the structure of the transaction dictates both the rules that determine whether the merger will be tax-free and the tax...