IRC 199A Deduction for Qualified Business Income
|
|
- Clementine Alexia Bridges
- 5 years ago
- Views:
Transcription
1
2 IRC 199A Deduction for Qualified Business Income
3 What is it? 20% deduction against qualified business income Designed to provide a tax break to owners of pass through entities, in light of substantial cut of C corporation rates from 35% to 21% Applies to owners of sole proprietorships, individually owned real estate, S corporations, and partnerships Regulations to be issued on application to tiered entities Deduction allowed to trusts and estates holding an interest in a pass through entity
4 What is it? Effective for tax years beginning after 12/31/2017 and before 1/1/2026 Double taxation issue still a concern, even with TCJA: Previous: 50.47% C Corp; 40.8% all others TCJA: 39.8% C Corp; 29.6% all others
5 What is Qualified Business Income? 199A(c) defines QBI as the ordinary income less ordinary deductions earned from a sole proprietorship, individually owned real estate, S corporation or partnership Does not include any wages or guaranteed payments received Excludes certain investment income: Short and long term capital gain/loss Dividend income Interest income
6 What is Qualified Business Income? 199A(d) requires QBI to be earned in a qualified trade or business Trade or business has many interpretations in tax law 469, 1411, 162 Currently defined as any trade or business other than: Trade or business of performing services as an employee A specified service trade or business
7 What is a Specified Service Business? Trade or business involving the performance of services in fields of: Health, law, accounting, actuarial science, performing arts, consulting, athletics, financial services and brokerage services Any trade or business where principal asset of such trade or business is the reputation or skill of its employees or owners Any business which involves investing and investing management, trading, or dealing in securities, partnership interests, or commodities
8 Mechanics of the Deduction Simply put, the deduction is equal to: LESSER of: 20% of QBI or The GREATER of: 50% of W2 wages paid or 25% of W2 wages paid plus 2.5% of basis of all qualified property
9 Mechanics of the Deduction BUT, there is an overall limitation! The deduction is limited to the LESSER of 20% of the combined QBI of the taxpayer or 20% of the excess of taxable income over any net capital gain Why the limit? To match the deduction with income taxed at ordinary rates, not income with a favorable long term capital gain rate
10 Mechanics of the Deduction Example of overall limit: A has $100,000 of QBI. In addition, A has $200,000 of long term capital gains, $20,000 of wages, and $50,000 of itemized deductions, for taxable income of $270,000. A's deduction is limited to the lesser of: 20% of QBI of $100,000, or $20,000, or 20% of ($270,000 $200,000), or $14,000.
11 W 2 Limitation Typical operating business 50% of allocable share of W2 wages paid by the business Real estate business 25% of allocable share of W2 wages plus 2.5% of basis of qualified property (more on this later) Cannot be management fees or payments to independent contractor The amount paid must be reportable on a payroll tax return
12 Allocable Share of W2 Wages S corporation shareholder Piece of cake! Pro rata, based on stock ownership Partnership partner A bit more tricky, due to potential special allocations 199A(f)(1) states a partner s share is determined in same manner as share of partnership s wage deduction
13 Example A has a 20% capital stake in ABC, LLC. Under the terms of the agreement, however, A is allocated 80% of any depreciation, but only 30% of Schedule K 1, Line 1 ordinary income Since A is being allocated 30% of the wage deduction via the Line 1 deduction, A receives 30% of the partnership s W2 wage expense for the limitation purposes
14 Basis of Qualified Property Any tangible property, subject to depreciation, held by the business at yearend Land and inventory do not count! Goodwill is also not eligible Used at any point during the year in the production of QBI Depreciable period of the asset must not have ended prior to the last day of the year in which basis is claimed for deduction Basis is not reduced by any depreciation
15 Depreciable Period of Qualified Property Starts on date the property is placed in service Ends on the later of: 10 years The last day of the last full year in the asset s regular depreciation period Any asset fully depreciated prior to 2018 will not count toward basis, unless placed in service after 2008
16 Example XYZ Co. purchases a piece of machinery on November 18, 2014 The machinery is used in the business, and is depreciated over 5 years Even though the depreciable life of the asset is only 5 years, the owners of XYZ Co. will be able to take the unadjusted basis of $10,000 into consideration for purposes of this adjusted basis limitation for ten full years, from , because the qualifying period runs for the longer of the useful life (5 years) or 10 years
17 Example Consider the same facts, only the asset is a non residential rental building that is depreciated over 39 years The shareholders of XYZ Co. will be able to take their share of the building's basis into consideration from , the last full year of the asset's depreciation schedule
18 Allocable Share of Qualified Basis Like the allocation of W2 wages, S corporations and partnerships have different nuances S shareholder: basis allocated pro rata based on stock ownership Partner: basis allocated in same manner in which depreciation expense is allocated to the respective partner
19 Exceptions! Taxable income of less than $315,000 MFJ removes the following limitations: W2 wage limit Property based limit Specified Service Businesses In other words, if an individual s taxable income, not including the 199A deduction, is less than these amounts: Any business can claim the deduction, regardless of the industry The deduction is simply 20% of the lesser of QBI or taxable income over capital gains
20 Exceptions! Once taxable income exceeds $415,000 MFJ, all limitations and exclusions fully apply Taxable income between the two? Ratable phase in of the wage and basis limitation Owners of specified service trade or businesses allowed a partial deduction
21 Other Considerations The 199A deduction is a below the line deduction No impact on various AGI thresholds Potential adverse state tax considerations Deduction cannot be taken in a loss year Negative QBI will be carried over and reduces QBI in following years calculations 199A deduction in a year with a Net Operating Loss NOL does not include the deduction
22 Title Text Non Real Estate Trade or Business Impact of Tax Cuts and Jobs Act Previous Law 20% Rule S Corporation Income $4,000,000 $4,000,000 Domestic Production Activities Deduction $(360,000) 0 Pass Through Deduction 0 $(800,000) Taxable Income $3,640,000 $3,200,000 Income Tax (highest marginal rate 39.6% in 2017; 37% in 2018) $1,441,440 $1,184,000 Net Investment Income Tax $ $ Federal Tax Savings from State and local income tax deduction $(64,865) $ State Tax on income (assumed 4.5% rate for all states combined) $163,800 $180,000 Total Tax under 2018 Tax Law $1,364,000 Total Tax under 2017 Tax Law $1,540,375 Savings under new tax law $176,375
23 Title Text Real Estate Business With Income Impact of Tax Cuts and Jobs Act Previous Law 20% Rule Partnership Income $750,000 $750,000 Pass Through Deduction 0 $(150,000) Taxable Income $750,000 $600,000 Income Tax (highest marginal rate 39.6% in 2017; 37% in 2018) $297,000 $222,000 Net Investment Income Tax $ $ Federal Tax Savings from State and local income tax deduction $(13,365) $ State Tax on income (assumed 4.5% rate for all states combined) $33,750 $33,750 Total Tax under 2018 Tax Law $255,750 Total Tax under 2017 Tax Law $317,385 Savings under new tax law $61,635
24 Title Impact of Tax Cuts and Jobs Act Text Real Estate Business With Loss Previous Law 20% Rule Partnership Income $(500,000) $(500,000) Pass Through Deduction 0 $ Taxable Income $(500,000) $(500,000) Income Tax (highest marginal rate 39.6% in 2017; 37% in 2018) $(198,000) $(185,000) Net Investment Income Tax $ $ Federal Tax Savings from State and local income tax deduction $8,910 $ State Tax on income (assumed 4.5% rate for all states combined) $(22,500) $(22,500) Total Tax under 2018 Tax Law $(207,500) Total Tax under 2017 Tax Law $(211,590) Savings (cost) under new tax law $(4,090)
25 IRC 163(j) Limitation on Business Interest Deduction
26 What is it? Limitation on the amount of interest expense businesses can deduct Effective for tax years beginning after 12/31/2017 Net business interest will be limited to 30% of adjusted taxable income
27 Adjusted Taxable Income Taxable income, without taking into account: EBITDA Non business income (e.g. gain from sale of assets held for investment) Business interest expense or business interest income Net operating loss deductions 20% QBI deduction Depreciation, amortization, or depletion Only through 2021 EBIT after
28 Exceptions to the Limitation Small businesses Average annual gross receipts of $25M or less the last three years Related taxpayers must be combined for this test (see 52, 414, and 1563) Electing real property business Those engaged in real estate development, construction, rental, management, or brokerage may elect out of rule Election is irrevocable Consequence? Those making the election are required to use the ADS lives for any nonresidential real property, residential real property and qualified improvement property
29 Summary of ADS Differences
30 Application to Pass Through Entities Interest limitation is applied at the entity level If 30% of ATI + interest income > interest expense incurred, excess passes through to owner as excess ATI and is taken into account to determine amount of business interest deducted by owner If 30% of ATI + interest income < interest expense: S corporation entity level carryover until enough income generated to absorb Partnership excess allocated to partners and carried over at the individual level until allocated income from that entity
31 Example X Co. has taxable income of $300,000 Included in that amount is $20,000 of interest income, $150,000 of interest expense, $200,000 of depreciation, and $20,000 of amortization X Co. computes its ATI as follows: $300,000 $20,000 + $150,000 + $200,000 + $20,000 = $650,000 The ATI is multiplied by 30%, resulting in a limitation of $195,000 The total limitation, however, is $195,000 plus interest income of $20,000, or $215,000 Since the interest expense of $150,000 is less than the limitation of $215,000, the interest is deductible in full
32 Example Assume the same facts, except taxable income was only $25,000 ATI is: $25,000 $20,000 + $150, ,000 +$20,000 = $375,000 30% limitation of $112,500 before adding interest income of $20,000 Total limitation is $132,500, so X Co. can deduct $132,500 of the $150,000 of interest expense
33 IRC 461(l) Excess Business Loss Rules
34 What is it? Yet another loss disallowance provision in the IRC, operating after: Basis limitations ( 1366, 704) At Risk limits ( 465) Passive activity limits ( 469) Simply, a taxpayer can only deduct net business losses up to $500,000 MFJ, regardless of how much nonbusiness income they may have
35 Mechanics Losses in excess of $500,000 are disallowed in the current year Carried forward Becomes a Net Operating Loss in the following year TCJA change to NOL rules! Can only carryforward (indefinite) 80% limitation on utilization MUCH unknown with this provision What to include in EBL calculation Essentially, what constitutes business income and loss?
36 Carried Interest Long term capital gains from an applicable partnership interest held less than three years recharacterized as short term capital gains Applicable partnership interest must be received in exchange for services Applies to tax years beginning after December 31, 2017
37 Q & A
38 Bonus Depreciation Now 100% for both new and used property Type of property eligible Tax life of < 20 years Must be placed in service after 9/27/17
39 Cost Segregation Impact The process is the same breakdown of assets into various tax categories (i.e. 5, 7 or 15 years) Bonus depreciation now applies to acquired properties, not just new construction! Impact example: $1,000,000 property acquisition
40 Qualified Property Rules Old Law Qualified Leasehold Improvements Qualified Restaurant Property Qualified Retail Improvements Qualified Improvement Property (39 year life) Only interior improvements to commercial buildings New Law Qualified Improvement Property (15 year life?) Impact Example: $500,000 renovation (assuming 15 year life)
41 Changes to 179 Deduction Old Law Could deduct up to $500,000 Phase out began at $2,000,000 Eligible property included: Tangible personal property (real property was not eligible) Software Qualified leasehold, restaurant or retail improvements New Law Can deduct up to $1,000,000 Phase out begins at $2,500,000 Eligible property includes: Tangible personal property and software Qualified Improvement Property Certain improvements to commercial property (i.e. roofs, HVAC, fire and alarm systems, security systems) Must be placed in service after 12/31/17
42 Q & A
43 Like Kind Exchanges Like Kind Exchanges have a long history. Have been around since 1921 Benefits Include: They allow you to deploy more cash into future deals Provides ability to diversify location and type of assets in your portfolio No limit to the number of exchanges you can do
44 General Rules of a Like Kind Exchange To qualify for non recognition of gain under 1031, relinquished property must be exchanged for replacement property of like kind for investment or use in trade or business In other words, three requirements must be met: 1. The exchanged properties must be of like kind to each other 2. The property must be held for investment, or use in a trade or business 3. There must be an exchange of properties
45 TCJA changes For exchanges completed after December 31, 2017 All real property other than real property held by the taxpayer as inventory is eligible Ancillary Personal Property may include taxable boot Washers, dryers, dishwashers, stoves, office equipment Courts have held that state law is generally followed to determine whether property is real or personal
46 Digging Deeper Related Party Exchanges o Generally, gain in a like kind exchange with a related party (related directly or indirectly) is triggered if either person disposes of exchanged property within two years Taking cash out of an exchange o Triggering Partial Gain o Cash Out Refinance post replacement purchase o Using Tenants in Common
47 Opportunity Zones
48 Opportunity Zones What s In it for Us? Capital Gain Deferral Gains from the sale of assets can be deferred until December 31, 2026 or the sale of the new investment, whichever is earlier Step up In Basis After a 5 year hold we get to exclude 10% of the original capital gain After a 7 year hold we exclude an additional 5% ~ 15% total Permanent Gain Elimination After 10 year hold, investors get to permanently exclude any capital gains tax on the post acquisition gains No dollar limitation on the amount of gain that can be deferred 1031 difference All asset classes are eligible Only have to reinvest gain No QI Losses given favorable treatment (Step Up on original deferral and get to take advantage of the loss upon disposition or )
49 Tax Deferral Timeline How do you achieve the 10 year holding period if gains are taxed on 12/31/2026?
50 Numerical Example
51 The Mechanics Invest the gain realized from the sale of an asset into an Opportunity Fund (OF) within 180 day limit Opportunity Fund must invest in QO Business Property QO Business Property is defined as: QO Zone stock QO Zone partnership interest QO Zone business property Original use commences with the QO Fund or the QO Fund substantially improves the property QO Zone Business
52 Anti Abuse/Limitations Must invest opportunity Fund to take advantage of: 15% gain exclusion by % gain exclusion by 2021 Appreciated gain excluded by 2026 Substantially Improved in a 30 month period Some think it may be difficult to do anything other than development or heavy repositioning Can t sell to related party The following trade or business will not qualify as an QOZ business Golf course, country club, massage parlor, hot tub facility, suntan facility, racetrack or other facility used for gambling, or a liquor store. Depreciation recapture current language uses the word gain. Recapture isn t normally considered gain therefore the conservative position is to plan on recapturing.
53 Other Issues Mixed Funds When mixing funds where only a portion of which is gain from the sale of an asset: Such investment shall be treated as 2 separate investments Only the rolled over gain is eligible for deferral & the step up Debt financing is available No depreciation allowed on initial investment on the reinvested gain Losses may be limited to investors due to basis
54 Resources Federal Resources IRS FAQ frequently asked questions CDFI Interactive Map Zones.aspx Each state has its own web resource guide Indiana Kentucky 144 sites in 84 counties Michigan _85624,00.html Ohio 320 census tracts in 73 counties
55 Q & A
2018 Income Tax Update - Commercial Real Estate
2018 Income Tax Update - Commercial Real Estate Stephen M. Lukinovich, CPA, PFS, CVA Andrew J. Ackermann, CPA, CVA Kentucky Commercial Real Estate Conference Louisville, KY October 30, 2018 Tax Cuts and
More informationHow Does Tax Reform Affect Real Estate Developers & Investors?
How Does Tax Reform Affect Real Estate Developers & Investors? FEBRUARY 20, 2018 TO RECEIVE CPE CREDIT Participate in entire webinar Answer polls when they are provided If you are viewing this webinar
More informationTax Cuts and Jobs Act. Issues Impacting the Real Estate Industry
Tax Cuts and Jobs Act Issues Impacting the Real Estate Industry Tax Cuts and Jobs Act Issues Impacting the Real Estate Industry On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act (the
More informationTax Cuts and Jobs Act Real Estate Industry Impact. April 30, 2018 Mary Beth Saylor, CPA Brent A. Wilkinson, CPA, JD
Tax Cuts and Jobs Act Real Estate Industry Impact April 30, 2018 Mary Beth Saylor, CPA Brent A. Wilkinson, CPA, JD Topics for Today Rate Changes Business Interest Limitation Net Operating Losses Excess
More informationNew Tax Rules. For You and Your Business Owners
New Tax Rules For You and Your Business Owners 199A-The 20% Deduction for Pass Throughs The New Rules for Meals & Entertainment QSBS-Qualified Small Business Stock And the New Depreciation Rules Presented
More informationThe Good, The Bad and the Ugly: Tax Reform in 2018 and Beyond
The Good, The Bad and the Ugly: Tax Reform in 2018 and Beyond Presenters: Timothy M. Tikalsky, CPA Date: May 18, 2018 1 RINA accountancy corporation www.rina.com Tax Cuts and Jobs Act Tax Cuts and Jobs
More informationK E Y N O T E S P E A K E R S
K E Y N O T E S P E A K E R S R o b e r t W i e b e, C P A Ro b e r t W @ w h h c p a s. c o m B e n H u b b e ll, C P A Be n H @ w h h c p a s. c o m 2 P R E S E N T A T I O N O U T L I N E 1. History
More informationTAX REFORM TCJA TAX CUTS AND JOBS ACT AL NELLA & CO, LLP CHRIS KOLLAJA & KEVIN TUSING HONE MAXWELL LLP AUBREY HONE
TAX REFORM TCJA TAX CUTS AND JOBS ACT AL NELLA & CO, LLP CHRIS KOLLAJA & KEVIN TUSING HONE MAXWELL LLP AUBREY HONE New Individual Tax Rates New rate structure with seven tax brackets 10% (same as 2017)
More information2017 Tax Cuts and Jobs Act: Impact on U.S. Real Estate Businesses
CLIENT MEMORANDUM 2017 Tax Cuts and Jobs Act: Impact on U.S. Real Estate Businesses January 30, 2018 The new tax act signed into law on December 22, 2017, popularly known as the Tax Cuts and Jobs Act (
More informationTAX REFORM Speakers: Brian Dethrow and Ron Kerridge
TAX REFORM Speakers: Brian Dethrow and Ron Kerridge Estate Planning Council of Central Texas CLE February 6, 2018 Jackson Walker L.L.P. 2018 C Corporations The Hottest Tax Shelter Jackson Walker L.L.P.
More informationTax Cuts and Jobs Act
Tax Cuts and Jobs Act 1. Deduction For Qualified Business Income IRC 199A a. The Tax Cuts and Jobs Act permits pass-through business owners, including partners of partnerships, S corporation shareholders
More informationTax Planning for Real Estate Under the TCJA
By now, you have been bombarded with summaries and articles on the 507-page tax bill, formerly known as the Tax Cuts and Jobs Act of 2017, and signed into law by President Trump on Dec. 22, 2017 (the Act).
More informationGAINING MOMENTUM IN OUR NEW TAX ENVIRONMENT: Moving Forward with Confidence
CLICK TO EDIT MASTER TEXT STYLES GAINING MOMENTUM IN OUR NEW TAX ENVIRONMENT: Moving Forward with Confidence Sno L. Barry, CPA, MST Cathy Jackson, CPA, MST CLICK TO EDIT MASTER AREAS TEXT OF INTEREST STYLES
More informationNew Tax Law: Issues for Partnerships, S corporations, and Their Owners
New Tax Law: Issues for Partnerships, S corporations, and Their Owners January 18, 2018 1 Introduction H.R. 1, originally known as the Tax Cuts and Jobs Act, was signed into law on December 22, 2017. The
More informationTax Reform Highlights
etax Alert Tax Reform Highlights Final Business/Corporate/Partnership Provisions in Tax Cuts and Jobs Act of 2017 Here is a chart that briefly summarizes the major provisions affecting our business clients,
More informationTax Benefits of Investing in Opportunity Zones
Tax Benefits of Investing in Opportunity Zones Bradley J. Sklar ASCPA Montgomery, Alabama Opportunity Zones Created as part of the Tax Cut and Jobs Act of 2017 Purpose of Opportunity Zones To generate
More informationTax Cuts and Jobs Act
Tax Cuts and Jobs Act Presenters: Timothy M. Tikalsky, CPA Date: February 6, 2018 1 RINA accountancy corporation www.rina.com Tax Cuts and Jobs Act Tax Cuts and Jobs Act (TCJA) Name given by House in H.R.
More informationTax Planning for Real Estate
Tax Planning for Real Estate Robert S. Keebler, CPA/PFS, MST, AEP Keebler & Associates, LLP Pass-thru Deduction Deduction equal to 20% of domestic qualified business income (QBI) from a passthrough entity
More informationHow Tax Reforms Impacts Your Vineyard February 8, Presented by: Kathy Freshwater, CPA Craig Anderson, CPA
How Tax Reforms Impacts Your Vineyard February 8, 2018 Presented by: Kathy Freshwater, CPA Craig Anderson, CPA Presenters Kathy Freshwater Tax Senior Manager Yakima Craig Anderson Tax Partner Yakima High
More informationWhat the Tax Cuts and Jobs Act Means for the Real Estate Industry
What the Tax Cuts and Jobs Act Means for the Real Estate Industry PRESENTED BY: ADAM HILL, CPA, PARTNER JON WILLIAMSON, CPA, MT, TAX MANAGER KIM PALMER, CPA, MT, PARTNER February 1, 2018 Welcome & Introductions
More informationBusiness Changes in the Tax Cuts and Jobs Act. Alan D. Sobel, CPA December 27,
Business Changes in the Tax Cuts and Jobs Act Alan D. Sobel, CPA December 27, 2017 Alan.sobel@sobelcollc.com 973-994-9494 Background Most significant tax legislation since 1986 503 pages of legislation
More informationWHAT IT MEANS FOR CONTRACTORS AND REAL ESTATE EXECUTIVES
Tax Reform: WHAT IT MEANS FOR CONTRACTORS AND REAL ESTATE EXECUTIVES Presented By: JOHN HELLER, CPA Manager Tax Services Group Agenda We will cover: Review Corporate Tax Changes Business Deduction Changes
More informationTax Cuts and Jobs Act of 2017 (TCJA) Key General Business Tax Provisions
Item IRC Expensing and Depreciating Section 179 Limits 179(b) For property service in For property service in The maximum Section 179 deduction and phaseout threshold are increased to $1 million and $2.5
More informationTAX CUTS & JOBS ACT DEVELOPMENTS
TAX CUTS & JOBS ACT DEVELOPMENTS P L A N N I N G F O R B U S I N E S S E S A N D I N D I V I D U A L S D E C E M B E R 1 2, 2 0 1 8 THE TAX CUTS & JOBS ACT AT A GLANCE BUSINESS PROVISIONS Reduced Tax Rates
More informationTax Cuts and Jobs Act Construction Industry Impact
Tax Cuts and Jobs Act Construction Industry Impact Presented By: Sean M. Auger, Partner 1 Introduction Most but not all provisions effective for tax periods beginning after December 31, 2017 2 General
More informationLowell and Lawrence, Massachusetts Renewal Communities Incentives
Lowell and Lawrence, Massachusetts Renewal Communities Incentives An Initiative of the U. S. Department of Housing and Urban Development based on tax incentives authorized by the Community Renewal Tax
More information5/29/ TAX CUTS AND JOBS ACT OVERVIEW. Individual Tax. Introduction-Individual Provisions. Dauphin County Bar Association May 30, 2018
2017 TAX CUTS AND JOBS ACT OVERVIEW Dauphin County Bar Association May 30, 2018 Individual Tax 2 Introduction-Individual Provisions In general, the individual provisions go into effect starting on January
More informationTax cuts and jobs act
1 Tax cuts and jobs act BUSINESS & INDIVIDUAL TAX PROVISIONS PRESENTED BY: MIKE AMERIO & MIKE SOVIK (2017): MFJ Bracket $0 - $18,500 10% $18,501 - $75,900 15% $75,901 - $153,100 25% $153,101 - $233,350
More informationTCJA Top Ten Tax Law Changes for Small Businesses DARBY RICH, CPA - TAX MANAGER MYRA BAKKE, CPA - TAX SHAREHOLDER
TCJA Top Ten Tax Law Changes for Small Businesses DARBY RICH, CPA - TAX MANAGER MYRA BAKKE, CPA - TAX SHAREHOLDER #1 Corporate Tax Rates New Corporate Flat Tax Rate of 21% replaces old graduated brackets
More informationThe Qualified Business Income Deduction Under the Tax Cuts and Jobs Act
The Qualified Business Income Deduction Under the Tax Cuts and Jobs Act By Julia Dengel, jdengel@bkd.com The Tax Cuts and Jobs Act (TCJA) made significant changes to corporate and individual taxation,
More informationUS Tax Reform: Impact on Private Funds
2018 INVESTMENT MANAGEMENT CONFERENCE CHICAGO US Tax Reform: Impact on Private Funds Adam J. Tejeda, New York Frank W. Dworak, Orange County January 31, 2018 Copyright 2018 by K&L Gates LLP. All rights
More informationTax Update: Legislative Developments and Tax Planning for Law Firms and Attorneys
Tax Update: Legislative Developments and Tax Planning for Law Firms and Attorneys Presented by Kristin Bettorf, CPA FM24 5/4/2018 4:15 PM The handout(s) and presentation(s) attached are copyright and trademark
More informationTax Reform: What You Need To Know
Tax Reform: What You Need To Know January 24, 2018 Presented by: Blake Harrison, CPA/PFS Senior Tax Manager LBMC Disclaimer This presentation is provided solely for the purpose of enhancing knowledge on
More information2017 Tax Reform What you need to Know
Oil & Natural Gas Accounting & Tax 2018 2017 Tax Reform What you need to Know November 8, 2018 J. Marlin Witt, CPA, CFP, CGMA What Makes Us Different, Makes You Better Overview of Reform Product of budget
More informationTax Credits for Small Wineries. Winery and Wine Distribution Law
Tax Credits for Small Wineries Winery and Wine Distribution Law Marc R. Greenough Foster Pepper PLLC Quincy, Washington August 5, 2008 Tax Credits for Small Wineries Under the Internal Revenue Code of
More informationOverview of TCJA Changes Affecting Businesses. Reduction in Corporate Tax Rate and Dividends Received Deduction
We have compiled the following summary of the Tax Cuts & Jobs Act. These changes are very extensive and we are still waiting on regulations to be written to explain some things in more detail. We will
More informationThe Tax Cuts and Jobs Act1 (TCJA) made
Significant Provisions of the Tax Cuts and Jobs Act Affecting Closely Held Businesses and Their Owners by Gerald A. Shanker The Tax Cuts and Jobs Act1 (TCJA) made significant changes to the Internal Revenue
More informationTax Reform: What Dealers Need to Know
Tax Reform: What Dealers Need to Know 1 Disclosure To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication is not intended or written
More informationDon t Let 2018 Be Taxing:
Don t Let 2018 Be Taxing: How Changes to the Tax Laws Change How We Counsel Businesses March 15, 2018 Agenda Introduction C corporation overview Pass-through overview Comparison 2 Introduction Types of
More informationChoosing a Business Entity After the New Tax Act and Other Important Business Tax Changes Under the New Law
Tax Advisory January 2018 Choosing a Business Entity After the New Tax Act and Other Important Business Tax Changes Under the New Law A Five-Part Series Part I: General - The Choice of Entity Decision
More informationBusiness Items from Tax Reform
Business Items from Tax Reform SCACPA Spring Splash Greenville, South Carolina May 18, 2018 Presented By: W. Verne McGough, Jr. Rogers, Townsend, & Thomas, P.C. 1221 Main Street, 14 th Floor Columbia,
More informationStructuring in the Face of the Pass Through Deduction, Interest Limitations and Immediate Depreciation
Structuring in the Face of the Pass Through Deduction, Interest Limitations and Immediate Depreciation Steven D. Bortnick Partner Tax Bortnicks@pepperlaw.com 609.951.4117 47616748v1 February 27, 2017 FEA
More informationOPPORTUNITY ZONES GAIN DEFERRAL AND ELIMINATION ADAM M. COHEN
OPPORTUNITY ZONES GAIN DEFERRAL AND ELIMINATION ADAM M. COHEN COLORADO OPPORTUNITY ZONES 2 OPPORTUNITY ZONE BENEFITS 1. Initial Gain Deferral 2. Initial Gain Reduction 3. O-Zone Gain Elimination 3 GAIN
More informationTAX REFORM CORPORATE & BUSINESS
The following chart sets forth some of the provisions affecting businesses in the Tax Reform Act of 2017 (the Act). This chart highlights only some of the key issues and is not intended to address all
More informationComparison of Current Tax Law, House and Senate Tax Reform Bills, and Conference Report. December 15, 2017 INSURANCE PROVISIONS...
Comparison of Current Tax Law, House and Senate Tax Reform Bills, and Conference Report December 15, 2017 INSURANCE PROVISIONS...2 COMPENSATION AND RETIREMENT SAVINGS PROVISIONS...5 GENERAL BUSINESS PROVISIONS...7
More informationREAL ESTATE REVIEW WINTER 2019
REAL ESTATE REVIEW WINTER 2019 BONUS DEPRECIATION TAX REFORM CHANGES MAKE COST SEGREGATION STUDIES ESSENTIAL TAX REFORM AND PARTNERSHIPS: WHAT YOU NEED TO KNOW THE POTENTIAL IMPACTS OF TAX REFORM TO REAL
More informationTax reform and the choice of business entity
The Adviser s Guide to Financial and Estate Planning: Tax reform and the choice of business entity Presented by: Steven G. Siegel, JD, LLM About the PFP Section & PFS Credential The AICPA Personal Financial
More informationTAX REFORM CORPORATE & BUSINESS
The following chart sets forth some of the provisions affecting businesses in H.R. 1, originally called the Tax Cuts and Jobs Act (the Act), as signed by President Donald Trump on December 22, 2017. This
More informationChannel Islands Chapter of the California Society of Enrolled Agents
Channel Islands Chapter of the California Society of Enrolled Agents IRS Regulations Clarify Business Pass-Through Deduction Article Highlights: Trade or Business Definition Qualified Business Income Limitation
More informationTo help organizations navigate the key provisions affecting businesses, we have summarized top provisions below.
HOW TAX REFORM IMPACTS BUSINESSES Summary On December 22, 2017, the President signed the Tax Cuts and Jobs Act (the "Act"). Signing the Act marked the largest change to U.S. tax policy in decades. Most
More informationOverview Snell & Wilmer
Overview History of Opportunity Zone Program Opportunity Zones Qualification and Designation Tax Benefits of the Opportunity Zone Program Opportunity Funds What are the rules, how do you qualify? Opportunity
More informationBusiness Provisions Under the Tax Cuts and Jobs Act Compared to Previous Tax Law
Tax Rates Corporate tax rate Top rate of 35 percent Flat rate of 21 percent (effective 1/1/2018) Alternative minimum tax (AMT) 20 percent Repealed; AMT credits refundable from 2018 through 2021 (1) Personal
More informationIMPACT OF NEW FEDERAL TAX LAW ON CHOICE OF BUSINESS ENTITY
IMPACT OF NEW FEDERAL TAX LAW ON CHOICE OF BUSINESS ENTITY Rob Wollfarth Shareholder 201 St. Charles Avenue, Suite 3600 New Orleans, Louisiana 504.566.8623 rwollfarth@bakerdonelson.com Introduction of
More informationBig Changes for Health Care Entities TA X C U T S & J O B S A C T O F
Big Changes for Health Care Entities TA X C U T S & J O B S A C T O F 2 0 1 7 OUR GOAL FOR TODAY Develop an awareness of the recent law changes that will affect healthcare organizations OUR GOAL FOR TODAY
More informationInvesting in Opportunity Act
Investing in Opportunity Act MODERATOR John Sciarretti Novogradac & Company LLP PANELISTS Joseph Bredehoft Husch Blackwell Jonathan Goldstein Advantage Capital Neil Faden Manatt, Phelps & Phillips LLP
More informationFor tax years beginning after 2017 and before 2026, the deduction under Sec. 199A is available to individuals and certain trusts, and estates that:
On August 8, the IRS has issued highly anticipated guidance regarding the brand-new code Sec. 199A which resulted from the Tax Cuts and Jobs Act ( TCJA ). As a quick refresher before discussing the recent
More informationMay 8, 2018 Watkins Glen, New York
May 8, 2018 Watkins Glen, New York This presentation is intended for general educational and/or informational purposes only and does not replace specific, independent professional advice. This presentation
More informationAdam Williams. Anthony Licavoli. Principal Tax Manager
1 2 Adam Williams Principal 734.302.4179 adam.williams@rehmann.com Anthony Licavoli Tax Manager 248.463.4598 anthony.licavoli@rehmann.com 3 4 5 What is your impression about the speed at which Congress
More informationMichael J. Reilly, CPA/ABV, CVA, CFF, CDA
Michael J. Reilly, CPA/ABV, CVA, CFF, CDA Key Tax Provisions in the Tax Cut and Jobs Act Michael J. Reilly, CPA/ABV, CVA, CFF, CDA - Tax Partner mreilly@dmcpas.com Tax Reform Seminar Embassy Suites by
More informationMichael J. Reilly, CPA/ABV, CVA, CFF, CDA Nicholas L. Shires, CPA
Michael J. Reilly, CPA/ABV, CVA, CFF, CDA Nicholas L. Shires, CPA Key Tax Provisions in the Tax Cut and Jobs Act Michael J. Reilly, CPA/ABV, CVA, CFF, CDA - Tax Partner Nicholas L. Shires, CPA - Tax Partner
More informationBusiness Tax. Pass-Through Entities. New 20% Deduction
Business Tax Pass-Through Entities New 20% Deduction For tax years beginning after Dec. 31, 2017, and before Jan. 1, 2026, taxpayers who have domestic qualified business income (QBI) from a partnership,
More informationTAX REFORM: IMPACT ON BUSINESSES AND INDIVIDUALS. February 8, 2018 Bruce I. Booken Rose K. Wilson
TAX REFORM: IMPACT ON BUSINESSES AND INDIVIDUALS February 8, 2018 Bruce I. Booken Rose K. Wilson The 2017 Tax Act Signed into law on December 22, 2017 Provisions apply NOW to taxable years beginning after
More informationTax Reform Impact on Private Equity Groups. private equity
Tax Reform Impact on Private Equity Groups 1 Today s Agenda Tax Reform Impact at the Fund Level Tax Reform Impact at the Portfolio Level Centralized Partnership Audit Rules Tax Reform Impact at the State
More information2018 Corporate/Business Tax Law Review
BUSINESS CONCEPTS MARCH 2018 2018 Corporate/Business Tax Law Review In our last tax article, we discussed how the 2017 Tax Cuts and Jobs Act (TCJA) brought many changes to individual income tax filers.
More informationChanges to S Corporation, Partnership and LLC Taxation under the Tax Cuts and Jobs Act
Changes to S Corporation, Partnership and LLC Taxation under the Tax Cuts and Jobs Act Morgan Klinzing, Pepper Hamilton LLP, Philadelphia, PA Mike Hauswirth, PwC, Washington, DC Ryan Dobens, PwC, Washington,
More informationOpportunity Zone Basics CDBA Peer Forum and Membership Meeting June 6, 2018
Opportunity Zone Basics 2018 CDBA Peer Forum and Membership Meeting June 6, 2018 The Objective 2 To get investors to invest in low income communities In general, Opportunity Zones are 25% (or 25, if more)
More informationTaking Advantage of Opportunity Zones: A Panel Discussion. Presented by Buchanan Ingersoll & Rooney Tampa October 2018
Taking Advantage of Opportunity Zones: A Panel Discussion Presented by Buchanan Ingersoll & Rooney Tampa October 2018 Florida Opportunity Zones Potential to eliminate poverty Areas with business activity
More informationOctober 31, Summary of Opportunity Zone Proposed Regulations. Table of Contents
Schuyler M. Moore D: 310.201.7559 F: 310.201.4444 SMoore@ggfirm.com October 31, 2018 To Colleagues, Friends, and Clients: Re: Summary of Opportunity Zone Proposed Regulations This letter provides a summary
More informationDemian and Company, LLC
Demian and Company, LLC 340 North Avenue East Cranford, NJ 07016 65 Milltown Road East Brunswick, NJ 08816 January 12, 2019 Overview New for 2018 Tax Extenders Updated Tax Rates Realtor Deductions Best
More informationTax Reform Update for Businesses and Individuals BOSTON NEWPORT PROVIDENCE SHANGHAI WALTHAM KAHNLITWIN.COM
Tax Reform Update for Businesses and Individuals BOSTON NEWPORT PROVIDENCE SHANGHAI WALTHAM KAHNLITWIN.COM Presented by LAURA H. YALANIS, CPA/MST SHAREHOLDER I work closely with clients to help them achieve
More informationTax Cuts and Jobs Act of 2017
Tax Cuts and Jobs Act of 2017 Important Highlights for Individuals and Small Businesses On December 15, 2017, Congress released the 2017 Tax Cut and Jobs Act ( the Act ) that has now passed both the House
More informationGuidance on Opportunity Zone Structuring & Capital Gain Deferral DECEMBER 12, 2018
Guidance on Opportunity Zone Structuring & Capital Gain Deferral DECEMBER 12, 2018 New IRC 1400Z-1 & 2 The new IRC 1400Z-1 & -2 establish an entirely novel & completely different regimen for deferring
More informationTax Incentives for Investments in Opportunity Zones: New Regulations Provide Clarity and More Questions
Tax Incentives for Investments in Opportunity Zones: New Regulations Provide Clarity and More Questions October 30, 2018 The 2017 Federal Tax Reform bill enacted a new set of tax incentives for investments
More informationBUSINESS DEDUCTIONS 510 Limitation on Deduction of Business Interest
BUSINESS DEDUCTIONS 510 Limitation on Deduction of Business Interest NEW LAW EXPLAINED Limitation on deduction of business interest for all taxpayers. The deduction of interest paid or accrued on a debt
More informationANALYSIS OF QUALIFIED OPPORTUNITY ZONES
March 15, 2018 Updated May 10, 2018 ANALYSIS OF QUALIFIED OPPORTUNITY ZONES This document provides a detailed analysis of the newly created tax incentives for investments in Qualified Opportunity Zones
More informationPartnerships and the Tax Cuts and Jobs Act (TCJA) Overview of new Sections 163(j), 199A, 1061 and selected other provisions of the TCJA
Partnerships and the Tax Cuts and Jobs Act (TCJA) Overview of new Sections 163(j), 199A, 1061 and selected other provisions of the TCJA Disclaimer EY refers to the global organization, and may refer to
More informationHFMA Annual AccounTing and AudiTing UpdaTe. Tax UpdaTe
HFMA Annual AccounTing and AudiTing UpdaTe Tax UpdaTe Presented by: Jeffrey J. Petrell, JD, CPA, CGMA Partner Health Care Tax Services Kelly A. Brocious, CPA Senior Manager Health Care Tax Services 97
More informationBusiness Tax Provisions
On December 22, 2017, President Trump signed the Tax Jobs and Cuts Act of 2017 (the Act). This will be the biggest tax overhaul in 30 years. The provisions below affect all entities from individuals to
More informationARIZONA OPPORTUNITY ZONES
July 18, 2018 ARIZONA OPPORTUNITY ZONES ARIZONA COMMERCE AUTHORITY OPPORTUNITY ZONES-WHAT ARE THEY? A mechanism to convert passive investment dollars into active investment dollars in underserved areas
More informationTax Cuts and Jobs Act Changes Impacting Real Estate. Presented by: Sefi Silverstein, CPA Len Nitti, CPA, MST
Tax Cuts and Jobs Act Changes Impacting Real Estate Presented by: Sefi Silverstein, CPA Len Nitti, CPA, MST Our Speakers Sefi Silverstein, CPA Len Nitti, CPA, MST 2 Housekeeping To submit questions use
More informationDepreciation and Expensing Opportunities Under Tax Reform
Depreciation and Expensing Opportunities Under Tax Reform CliftonLarsonAllen (CLA) Disclaimers The information contained herein is general in nature and is not intended, and should not be construed, as
More informationThe Investment Lawyer
The Investment Lawyer Covering Legal and Regulatory Issues of Asset Management VOL. 25, NO. 3 MARCH 2018 REGULATORY MONITOR Private Funds Update By Frank Dworak and Adam Tejeda The Tax Cuts and Jobs Act
More informationTax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Corporations
Presenting a live 90-minute webinar with interactive Q&A Tax Reform for Pass-Through Entities: Impact of New Tax Law on Partnerships, LLCs and S-Corporations Planning Techniques, Loopholes, Qualified Business
More informationTax Reform What Are the Implications on M&A Structuring. Analysis of the TCJA and Tax Planning Under the New Law February 14, 2018
Tax Reform What Are the Implications on M&A Structuring Analysis of the TCJA and Tax Planning Under the New Law February 14, 2018 About Plante Moran Plante Moran is one the nation s largest certified public
More information2018 Federal Income Tax Update Business
2018 Federal Income Tax Update Business FTU- Business IRC 199A ISSUES 2 Business Tax Changes Under the Tax Cuts and Jobs Act The Tax Cuts and Jobs Act of 2017 (the Act ) contains significant legislation
More informationTax Reform Update and Q&A Session October 18, 2018
Tax Reform Update and Q&A Session October 18, 2018 Moderated By: Brian Ray, MS, CPA This presentation has been prepared for informational purposes only, and is not intended to or should be relied upon
More informationTax Reform Webinar January 4, 2018
Tax Reform Webinar January 4, 2018 Speakers: Jerry Frumm Vice Chairman & Chief Investment Officer, Senior Lifestyle Jeanne McGlynn Delgado, Vice President Government Affairs, ASHA Randy Hardock Partner,
More informationFederal Tax Brackets for Startup Businesses In 2018
Federal Tax Brackets for Startup Businesses In 2018 Federal Income Tax Brackets by Business Type (Single Taxpayer) Type 2017 2018 C CORPORATION Corporate Income Tax 15% - $0 to $50,000 25% - $50,000 to
More informationComparison of House and Senate Tax Reform Bills
Comparison of House and Senate Tax Reform Bills Provision Individual Rates (Single) 12% $0 - $44,999 25% $45,000 - $199,999 35% $200,000 - $499,999 39.6% $500,000 + Senate Version of H.R. 1, the 10% $0
More informationGovernment Affairs. The White Papers TAX REFORM.
Government Affairs The White Papers TAX REFORM www.independentagent.com January 3, 2018 Below is a summary of the provisions of the new tax reform law that are most likely to impact Big I members. This
More informationTax Cuts & Jobs Act: Considerations for Funds
Tax Cuts & Jobs Act: Considerations for Funds December 22, 2017 On December 22, 2017, the President signed into law the 2017 U.S. tax reform bill formerly known as the Tax Cuts & Jobs Act (the TCJA ).
More informationSPECIAL REPORT. Tax Law Essentials. Brought to you by Mercer Advisors
SPECIAL REPORT Tax Law Essentials Brought to you by Mercer Advisors Game-changing tax package The recently enacted Tax Cuts and Jobs Act (TCJA) is a sweeping, game-changing tax package. Here s a look at
More information12/19/2018 THOUGHTWARE. Financial Services THOUGHTWARE. Tax Reform Update. Income Tax Update for Financial Institutions
THOUGHTWARE Financial Services THOUGHTWARE Financial Services Tax Reform Update Income Tax Update for Financial Institutions December 20, 2018 1 To Receive CPE Credit Individuals Participate in entire
More informationInvesting in Opportunity Zones
Investing in Opportunity Zones for the 2018 Defense Communities National Summit Gregory Clements Partner, Dover Novogradac & Company LLP gregory.clements@novoco.com Taxpayers can get capital gains tax
More informationThe 2017 Tax Reform Act: What Lawyers Should Know
The 2017 Tax Reform Act: What Lawyers Should Know Mark E. Gingrich, CPA, J.D. Tax Member Chris J. Harris, CPA, J.D. Tax Senior I Agenda I. 20% deduction under Sec. 199A II. Depreciation / like-kind exchange
More informationTax Cuts & Jobs Act W H AT B U S I N E S S E S & I N D I V I D U A L S N E E D T O K N O W D E C E M B E R 1 2, 2018
Tax Cuts & Jobs Act W H AT B U S I N E S S E S & I N D I V I D U A L S N E E D T O K N O W D E C E M B E R 1 2, 2018 WHAT WE WILL COVER TODAY 1 2 Business & individual provisions of the Tax Cuts and Jobs
More informationTax Cuts and Jobs Act. Durham Chamber of Commerce Public Policy Meeting January 9, 2018
Tax Cuts and Jobs Act Durham Chamber of Commerce Public Policy Meeting January 9, 2018 Tax Cuts in Billions Corporate/Business ($653) S-Corps/Partnership/Sole Proprietor ($414) International Tax Changes
More informationTax Cuts and Jobs Act Questions and Answers for Small Businesses
Tax Cuts and Jobs Act Questions and Answers for Small Businesses February, 2018 This is a summary of items that are subject to variations and exceptions. It is not to be relied upon as tax advice. For
More informationIMPACT OF TAX REFORM ON COMMERCIAL REAL ESTATE. Mary Burke Baker, Government Affairs Counselor K&L Gates, LLP
IMPACT OF TAX REFORM ON COMMERCIAL REAL ESTATE Mary Burke Baker, Government Affairs Counselor K&L Gates, LLP MOST SWEEPING TAX REFORM SINCE 1986 Tax Cuts and Jobs Act signed December 22, 2017 Generally
More informationFriday, 26 January 2018 WRM # TOPIC: Decoding Tax Reform: Pass-Through Entities Part 1 The 20% Deduction for Qualified Business Income.
The WRMarketplace is created exclusively for AALU members by experts at Greenberg Traurig and the AALU staff, led by Jonathan M. Forster, Steven B. Lapidus, Martin Kalb, Richard A. Sirus, and Rebecca S.
More information