Sourcing Sec. 751(a) gain from nonresident’s sale of California partnership interest
Tax practitioners should be aware of the The California Franchise Tax Board’s two-step approach to transactions involving Sec. 751 gain.
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Tax practitioners should be aware of the The California Franchise Tax Board’s two-step approach to transactions involving Sec. 751 gain.
Practitioners may face a difficult analysis in helping their clients understand their possible PTE election opportunities.
This item focuses on income classification and revenue-sourcing issues, with California law used to illustrate how states may address such issues.
This item discusses Illinois Legislature's S.B. 2531, which includes a PTE tax that allows a workaround to the federal $10,000 limitation for state and local tax deductions.
The COVID-19-related downturn and its impact on commercial property values offers an opportunity to claim favorable valuations on returns as they are filed or to challenge valuations from state taxing authorities.
The total tax owed by a trust can be significantly affected by the location of grantors, beneficiaries, trustees, and even trust assets.
This item examines the complex approaches used by Colorado, Maryland, and Oregon to adopt the IRC on a rolling basis.
COVID-19 has added to employers' compliance requirements.
States’ approaches to TCJA and CARES Act conformity will be driven by budget estimates and whether they can follow the reduction to the federal taxable income base while still balancing their budgets.
The TCJA's interest expense deduction limitation rules in amended Sec. 163(j) create significant challenges and uncertainty for taxpayers at the state level.
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.
The interplay between Sec. 163(j) and state expense disallowance leaves taxpayers in a position of having to make important decisions in a vacuum of guidance.
Plans adopted by some states sidestep the new federal Sec. 164(b)(6) limitation, which may not apply to income taxes imposed on a PTE.
Review the various approaches states use to account for the GILTI and FDII regimes introduced by the TCJA.
The IRS issued guidance on the tax treatment of state and local refunds now that taxpayers are limited to a $10,000 deduction on their individual tax returns.
Post-TCJA, practitioners and taxpayers should be aware of potential state conformity issues in areas including interest expense deductions, qualified business income, net operating losses, and alternative minimum taxes.
This article offers guidance on maximizing the use of corporate state NOLs, recording deferred tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.
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.
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.
Rules addressing state taxation of gains or losses that arise from the sale of interests in a passthrough entity are complex and differ from state to state.
DEDUCTIONS
Business meal deductions after the TCJA
This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.
TAX RELIEF
Quirks spurred by COVID-19 tax relief
This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.