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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...

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...

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...

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...

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...

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 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...

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...

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...

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...

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...

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...

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...

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...

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...

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...

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'...

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...

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...

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...

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...

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...

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...

Tax shelters generally follow the letter of the Internal Revenue Code but produce results that the Code never intended, such as tax losses that offset a taxpayer's capital gains or other income, often with minimal costs to the taxpayer. READ NOW...

With the IRS announcing the 2023 cost-of-living-adjusted limits that apply to qualified plans in Notice 2022-55 , notably, the new 401(k) elective deferral limit rising 10% (to $22,500), now is a good time for 401(k) plan sponsors to remind participants...