Friday, August 21, 2020

New Unified High-Tax Election Brings Planning Challenges - Law360

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Not to change the topic here:

With elections coming, Texas Republican leaders join the thin blue line | The Texas Tribune

And there was a provocative hot take on Twitter from former state Rep. Matt Rinaldi , an Irving Republican and attorney, poking another easy hole in the proposal: "Does the Gov want to provide an incentive for voters to support defunding police by tying it to a property tax freeze? This is a weird approach."

Taken at face value, what the governor and his sidekicks proposed would do just what Rinaldi suggested. They said any cuts to local police budgets should be answered with freezes on any increases in local property tax revenues. Someone bent on corralling local spending could get allies at City Hall to cut the police budget and freeze taxes forever; it's easier than arguing over taxes and property valuations every year.

Publisher: The Texas Tribune
Date: 2020-08-21T09:00:00 00:00
Author: Ross Ramsey
Twitter: @TexasTribune
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Proposed Regulations Provide Guidance on Taxation of Carried Interests | BakerHostetler - JDSupra

On July 31, the IRS and the Treasury Department released long-awaited proposed regulations on the Section 1061 “carried interest” rules. The proposed regulations include extensive definitional and operational rules on the application of Section 1061, but leave important questions unanswered. The proposed regulations also include related amendments to existing regulations under Sections 702, 704 and 1223.

A carried interest is an interest in partnership profits that is transferred to a service provider, such as a fund manager, in excess of any contributed capital in exchange for investment- and management-related services. Historically, a carried interest partner could recognize long-term capital gain with respect to the interest by way of partnership allocations or on its sale.

Publisher: JD Supra
Twitter: @jdsupra
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Senior Manager - Domestic Tax - DFIN | Built In Chicago

Donnelley Financial Solutions (DFIN) is a leading global risk and compliance solutions company. The Company provides regulatory filing and deal solutions via its software-as-a-service ("SaaS"), technology enabled services and print and distribution solutions to public and private companies, mutual funds and other regulated investment firms, to serve their regulatory and compliance needs.

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Quite a lot has been going on:

IRS Issues Proposed Regulations on the Taxation of Carried Interests - Lexology

Section 1061, enacted as part of the Tax Cuts and Jobs Act of 2017 (the “ TCJA ”), modifies the taxation of carried interests (e.g., special allocations to the general partner of an investment fund). In general, Section 1061 increases the required holding period to obtain long-term capital gain treatment (from one year to three years) for gain allocated to a service provider with respect to an “applicable partnership interest” (“ API ”).

In general, an API does not include (i) any partnership interest held directly or indirectly by a corporation (the “ Corporate Exception ”) or (ii) any capital interest in a partnership that gives the taxpayer a right to share in partnership capital based on (1) the amount of capital contributed or (2) the value of such interest subject to tax under Section 83 upon receipt or vesting (the “ Capital Interest Exception ”).

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The basics of a tax-free spin-off transaction in a corporate restructuring | Accounting Today

Under the U.S. corporate income tax system, there is generally a tax imposed both at the corporate level and at the shareholder level. Upon distribution of appreciated property to its shareholders, a corporation generally recognizes taxable gain as if it had sold the property for fair market value, and the shareholders will generally recognize taxable gain upon receipt of the distributed property.

There are several types of transactions commonly referred to as "spin-offs." A spin-off occurs where one corporation (i.e., a parent) distributes stock of a controlled corporation (i.e. a subsidiary) to its shareholders, generally on a pro rata basis. A split-off occurs where the parent distributes stock of the controlled corporation to some of its shareholders in exchange for their stock in the distributing parent.

Publisher: Accounting Today
Date: 2020-08-20T19:03:14.028
Author: https www accountingtoday com author james w standard jr
Twitter: @AccountingToday
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States with the most small businesses | Your Money | henryherald.com

To uncover the states with the most small businesses, The Simple Dollar consulted the SBA's 2020 Small Business Profiles report . States were ranked by the total number of businesses with less than 500 employees in their state.

million people. That's 47.3%—nearly half—of America's combined workforce. Most work for businesses that employ fewer than 100 people.

To uncover the states with the most small businesses, The Simple Dollar consulted the SBA's 2020 Small Business Profiles Report . States were ranked by the total number of businesses with less than 500 employees in their state. Naturally, there's a correlation with population—small and/or sparsely populated states dominate the bottom of the list and large, populous states are concentrated at the top.

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Publisher: Henry Herald
Author: Andrew Lisa
Twitter: @thehenryherald
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INSIGHT: The 5 Most Common Tax Reportable Crypto Events
Twitter: @tax
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