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Archive for the ‘Partnerships and LLCs’ Category

Steve Looney Presents Section 199A and Pass-Through Entities Seminar at NYU Taxation Institute

Published: November 15th, 2018

Stephen R. Looney

Stephen Looney, chair of Dean Mead’s Corporate and Tax Department, recently co-presented seminars on “Section 199A and Its Application to Pass-Through Entities” at the NYU School of Professional Studies 77th Institute on Federal Taxation – “A Year of Insights and Analyses From America’s Top Tax Authorities.” During his presentation sessions held on October 25 in […]

Qualified Opportunity Zones – Recent IRS Proposed Regulations

Published: November 13th, 2018

Stephen R. Looney

On October 19, 2018, the IRS issued Proposed Regulations addressing new Sections 1400Z-1 and 1400Z-2 relating to Qualified Opportunity Zones. Among other things, the Proposed Regulations confirmed that only capital gains (short-term or long-term) can be deferred under Section 1400Z-2. Section 1400Z-2 permits a taxpayer to defer recognition of a capital gain if an amount […]

IRS Issues Proposed Regulations on Section 199A Deduction

Published: August 9th, 2018

Stephen R. Looney

On August 8, 2018, the IRS issued Proposed Regulations under Section 199A as enacted by the Tax Cuts and Jobs Act, which generally provides a deduction of 20% of an owner’s allocable share of the “qualified business income” (“QBI”) from a pass-through entity (S corporation, partnership, LLC taxed as a partnership) or sole proprietorship. The […]

Brad Gould Earns Florida Bar Board Certification in Tax Law

Published: June 21st, 2018

Brad Gould

Fort Pierce, FL — Dean, Mead, Minton & Zwemer announced today that Brad Gould, shareholder in the Fort Pierce office, has earned Board Certification in Tax Law from The Florida Bar Board of Legal Specialization & Education. This is a significant milestone in Gould’s legal career because he is now distinguished as a specialist and […]

Actual Economic Outlay Doctrine Lives On

Published: May 31st, 2018

Stephen R. Looney

A back-to-back loan in the S corporation context refers to an arrangement in which an S corporation shareholder borrows funds from an unrelated or related third party, and then lends such funds to the S corporation.  A loan may be structured as a back-to-back loan at the outset to enable the shareholder to obtain a […]

Litigation Client Alert – Changes to Florida LLC Law

Published: February 6th, 2018

A. Felipe Guerrero

In 2013, the Florida Legislature adopted a new LLC act that created Chapter 605 of the Florida Statutes. The revised law became effective for all Florida limited liability companies on Jan. 1, 2015, regardless of when they were organized. The Florida Legislature adopted amendments to Chapter 605 that became effective on July 1, 2015. Many disputes […]

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

Published: December 29th, 2017

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

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 […]