When the sale of an interest in a PTE is contemplated, planning for state sourcing and taxability of the gain should both be considered so the owners avoid a large — and sometimes unexpected — state income tax liability.
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Tax Planning; Tax Minimization
Consequences of the MTC’s new interpretation of P.L. 86-272
Although the MTC’s revised interpretation will greatly restrict protections from state income taxes for some taxpayers, it could also present them with planning opportunities.
Cryptoasset mining and state tax incentives
This item describes state tax incentives available to businesses that operate data centers, including those used for cryptoasset “mining.”
Where individual, corporate, and passthrough entity taxation meet
Passthrough owners must consider many risks and
uncertainties, in addition to political trends on Capitol Hill, before opting into a state-level regime designed to bypass the $10,000 SALT deduction cap created by the TCJA.
Property tax relief planning during times of COVID
While the impact of lost wages and retail receipts was felt almost immediately in city coffers, property assessments are only now starting to take effect — and most assessors have massive budget holes to fill.
Managing state taxes in an uncertain world
Businesses with employees working remotely in a new location as a result of the pandemic should
carefully evaluate the rules in those states to ensure proper withholding.
Donations to charities in exchange for SALT credits
The IRS provided guidance regarding limitations on the deductibility of charitable contributions made in exchange for state and local tax credits.
IRS issues additional regs. on charitable organization payments in lieu of state and local taxes
The IRS issued additional final regulations on payments made to charitable organizations in lieu of state and local tax credits.
Final regs. issued on payments to charitable organizations
The IRS issued additional final regulations on payments made to charitable organizations in lieu of state and local tax credits.
Amended California EITC: Fiscal impact and effects on taxpayers
This discussion summarizes both versions of the CalEITC and how the 2019 amendments affect the calculation and the credit’s desired effects.
SALT deduction cap rules finalized, safe harbor proposed
Here are details on the new rules that deny a federal tax deduction to taxpayers who donate to a state charitable fund and receive a state or local tax credit in return.
Proposed rules aimed at states’ attempts to avoid the $10,000 SALT limit
Here is what practitioners need to know about the IRS’s proposed rules that would curb the deductibility of charitable contributions that qualify for state and local tax credits.
Proposed rules would curb avoidance of SALT deduction limit
Here is what practitioners need to know about the IRS’s proposed rules that would curb the deductibility of charitable contributions that qualify for state and local tax credits.
North Carolina’s nonconformity to federal bonus depreciation: Mechanics and planning opportunities
Noncorporate taxpayers have the ability to determine how unused future bonus depreciation
deductions are used when transferring assets in a nonrecognition or “basis carryover” event.
Debtor Down but Additional Child Tax Credit Is Out
The Eighth Circuit held that the additional child tax credit qualifies as a public-assistance benefit under Missouri law and thus was exempt from a debtor’s bankruptcy estate.
The Power of Entertainment Tax Credits
Many states have created tax credits to attract movie and television productions to their states. The most powerful incentives over the last decade have been state income tax credits.
Repeal of the California Enterprise Zone Tax Credit Program
California eliminated the California Enterprise Zone Tax Credit program and replaced it with a more limited hiring credit.
Federal Income Tax Treatment of Certain Transferable State Tax Credits
The emergence of online marketplaces and auction houses has provided a single point of contact for both sellers and buyers, making sales and purchases of transferable state tax credits more common.
Refundable State and Local Tax Credits
The IRS has not issued published guidance on corporations’ tax treatment of refundable state and local tax credits. However, the Office of Chief Counsel, through a recent legal memorandum and other informal nonprecedential advisories, has provided insight as to the treatment of these credits.
State Research Credits
Practitioners with clients conducting qualified research could find some hidden gems among state research credits
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
