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Archive for the ‘Corporate’ Category

2018 Florida Legislature Enacts Numerous State and Local Tax Changes

The Florida Legislature concluded its 2018 Regular Session on Sunday, March 11, 2018.  Prior to the start of the session, the Legislature filed 3,189 bills for consideration.  At the conclusion of the extended 62 day session, only 200 bills were passed.[1]  While these bills are subject to approval or veto by Governor Scott, we summarize […]

Legislative Update: The Federal Tax Cuts and Jobs Act and the Risk for Florida Corporate Taxpayers

Published: February 16th, 2018

By: H. French Brown, IV

This is an update to our previous article, Eyes on the Legislature: The Federal Tax Cuts and Jobs Act and the Risk for Florida Corporate Taxpayers written by Michael B. Dobson & Robert S. Goldman.  That article provided a general overview of how Florida’s corporate income tax “piggybacks” the Internal Revenue Code, and how the Florida […]

Eyes on the Legislature: The Federal Tax Cuts and Jobs Act and the Risk for Florida Corporate Taxpayers

Published: January 9th, 2018

By: Michael B. Dobson Robert S. Goldman

This is an alert to corporations subject to the Florida corporate income tax: The impact of the recently enacted Federal Tax Cuts and Jobs Act (“Act”) on Florida tax revenue is unknown. During its 60 day regular session beginning today January 9, 2018, the Legislature will invariably consider whether the Act is likely to result […]

New Deduction For Qualified Business Income of S Corporations, Partnerships, LLCs and Sole Proprietorships

Published: December 29th, 2017

By: Stephen R. Looney

Effective January 1, 2018, the Tax Cuts and Job Act, formally entitled “An Act to Provide For Reconciliation Pursuant to Titles II and IV of the Concurrent Resolution on the Budget for Fiscal Year 2018” (the “Tax Act”), enacts new Internal Revenue Code (“Code”) Section 199A which generally provides a deduction of 20% of the […]

Built-In Gain Tax Not Triggered By S Corporation Conversion of LLC Interest

Published: October 18th, 2017

By: Stephen R. Looney

An S corporation that was previously a C corporation is subject to the built-in gains tax under Section 1374 if appreciated assets held by the corporation (measured from the beginning of the S corporation’s first taxable year) are disposed of during the “recognition period.”  The built-in gains tax is imposed at the corporate, rather than […]

ESOP Participants Treated as Related Persons for Deduction Deferral Purposes Under Section 267(a)(2)

Published: October 13th, 2017

By: Stephen R. Looney

Section 267(a)(2) contains a matching rule which requires that deductions resulting from items of expense and interest may not be taken in an earlier taxable year from the one in which the payee includes such item is gross income if the payor and payee are “related persons” within the meaning of Section 267(b).  Accordingly, whether […]

Tax Court Holds Income was Improperly Attributed to S Corporation

Published: March 28th, 2017

By: Stephen R. Looney

In a recent case, the Tax Court addressed the issue of whether income should be reported by a Taxpayer providing services or an S corporation established by the Taxpayer. Taxpayers often seek to report income generated from services provided through an S corporation on such S corporation’s tax return, but as the case below demonstrates, […]

IRS’s Informal S Corporation No-Rule List Includes Three New Items

Published: March 16th, 2017

By: Stephen R. Looney

A taxpayer may, for a fee, request a written letter ruling from the IRS interpreting and applying tax laws to the taxpayer’s represented set of facts. However, there are some issues in which the IRS will not issue a letter ruling. Taxpayers should note that the IRS has recently added three new issues to its […]