When a company is involved in litigation—as either a plaintiff or a defendant—it is essential that the management team and legal counsel consider the potential tax implications of the action as early as possible. Advance planning and consultation can have a major impact on both the tax treatment of any proceeds and the deductibility of attorneys’ fees and other expenses. (more…)
In December of 2017, the Tax Cuts and Jobs Act was enacted by Congress, which gave us the most sweeping and dramatic changes to the Internal Revenue Code in more than 30 years. The Act created the Internal Revenue Code Section 199A deduction which has the potential to help taxpayers reduce their liabilities with a 20% deduction against their “qualified business income”. Section 199A provides individual taxpayers and certain trusts and estates a deduction for qualified business income from a partnership, limited liability company, S-corporation, sole proprietorship, trust or estate. The deduction applies to tax years beginning after December 31, 2017 and before January 1, 2026. (more…)
The Tax Cuts and Jobs Act (TCJA), signed into law in December 2017, made important modifications to the income taxation of trusts and estates for 2018 and beyond. Trust and estate income tax rates and brackets changed, along with deductibility of some estate and trust administrative expenses. Also, a new qualified business income deduction is available, under certain circumstances, that could be as much as 20% of qualified business income. (more…)
With the signing of the Tax Cuts and Jobs Act (TCJA) in December 2017, valuation analysts have been tasked with incorporating the changes to the tax law into their analysis. Changes, such as the lowering of corporate tax rates and restrictions on interest deductibility, must be factored into valuation analysis to capture the effects of the TCJA on company value. When valuing a US company, valuation analysts must now consider the following: (more…)
The Tax Cuts and Jobs Act (TCJA) completely rewrites sections of the tax code for individuals and businesses. Under the TCJA, the federal gift and estate tax exemption doubles from $5 million to $10 million, indexed for inflation to $11.18 million in 2018.
Somewhat lost in the clamor is the fact that the new law preserves the “portability” provision for married couples. Portability allows your estate to elect to permit your surviving spouse to use any of your available estate tax exemption that is unused at your death. (more…)
A loophole in the Tax Cuts and Jobs Act (TCJA) could allow multinational corporations like Apple to avoid paying billions of dollars in taxes on profits stashed overseas.
The TCJA imposes a transition tax on untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated. But the law contains a loophole that allows taxpayers to convert income that would otherwise be taxed at 15.5% (cash holdings) into income that is taxed at 8% (more illiquid investments).
And multinationals could have leeway to shift foreign earnings into the 8% tax bracket. (more…)
The Tax Cuts and Jobs Act (TCJA), which generally went into effect at the beginning of 2018, lowers individual and corporate tax rates, reduces or eliminates many deductions and enhances other tax breaks. One thing the new law doesn’t do is repeal the federal estate tax. But the TCJA does include other provisions that can impact your estate plan. (more…)