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Archive for the ‘Partnerships and LLCs’ Category

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 […]

Tax Court Finds Compensation Paid to Shareholder-Employees Reasonable

Published: July 28th, 2016

By: Stephen R. Looney

In Johnson, Inc.,[1] the Tax Court held that the amounts paid to the shareholder-employees of a C corporation constituted reasonable compensation deductible under Section 162 and that amounts paid by the taxpayer-corporation to an entity controlled by two of its shareholders was deductible as an ordinary and necessary business expense under Section 162. Facts of […]

Bipartisan Budget Act of 2015

Published: June 29th, 2016

By: Charles H. Egerton

Charlie Egerton, shareholder in Dean Mead’s Tax Department, discusses the revolutionary audit rules that are a part of the Bipartisan Budget Act of 2015 and how they affect entities treated as partnerships for tax purposes. Bipartisan Budget Act of 2015

Starting a Business – An Alphabet Soup of Choices (of Entity)

Published: April 18th, 2016

By: Dana M. Apfelbaum

Starting and running a business requires making many important decisions. The very first decision faced by many business owners is what kind of entity should be formed to operate their business. In Florida, there are a number of available options. While the decision can be daunting, the variety in flavor of business entities provides the […]

Steve Looney speaks at the 68th Alabama Federal Tax Clinic

Published: December 1st, 2014

By: Stephen R. Looney

Stephen Looney, shareholder and chair of Dean Mead’s Tax Department, spoke at the 68th Alabama Federal Tax Clinic in Tuscaloosa, Alabama on November 21, 2014. He presented on “S Corporation Hot Topics.” The outline from his presentation may be viewed HERE.

Steve Looney Speaks at 60th Annual William & Mary Tax Conference

Published: November 12th, 2014

By: Stephen R. Looney

Steve Looney, shareholder and chair of Dean Mead’s Tax Department spoke at the 60th Annual William & Mary Tax Conference in Williamsburg, VA, on November 7, 2014. He presented on “Reclassification Risks For Compensation Paid by S and C Corporations to Shareholder-Employees“. In addition to covering unreasonably high compensation in the “C” corporation context and unreasonably […]

Steve Looney Speaks at 63rd Tulane Tax Institute in New Orleans

Published: October 24th, 2014

By: Stephen R. Looney

Stephen R. Looney, Chair of Dean Mead’s Tax department, was a guest speaker at the 63rd Annual Tulane Tax Institute in New Orleans, LA on October 22, 2014. His presentation was titled, “Reclassification of Compensation Paid by C Corporations and Reclassification of Distributions Made by Corporations to their Shareholder-Employees”. Mr. Looney discussed how the IRS and […]