Federal Taxation

  • Rising Interest Rates are an Opportunity to Deduct Capital Loss Carryovers

    By:
    Thomas J. Boczar and Jeff Markowski
    |
    Jun 1, 2018

    Some companies currently face two concurrent challenges—first, how to accelerate the utilization of otherwise non-deductible capital loss carryovers for tax purposes and second, how to guard against the impact of rising interest rates.

  • Does Lender Management Provide Family Offices with a Roadmap for Obtaining an IRC section 162 Trade or Business Expense Deduction in Connection with Providing Investment Management Services?

    By:
    Kevin Matz, Esq., CPA, LLM (taxation)
    |
    Jun 1, 2018

    Lender Management, LLC v. Commissioner of Internal Revenue provides family offices with a potential roadmap for obtaining trade or business expense deductions under IRC section 162 in connection with rendering investment management services.

  • Is That Loss Actually Deductible On Your Cannabis Investment or Loan?

    By:
    Peter Metz, CPA, and John Pellitteri, CPA
    |
    Jun 1, 2018

    At the federal level, cannabis businesses that “touch the leaf” are taxed on the sum of revenue less cost of goods sold, according to IRC section 280E. Businesses that do not touch the leaf—meaning those that indirectly benefit from cannabis activity, such as suppliers and landlords—can also claim other deductions. But if there is a loss on your investment or loan, will the loss be deductible? Although the investment might appear rosy right now, storm clouds could one day come to this industry. 

  • Taking Full Advantage of the R&D Tax Credit: Tips for Identifying, Gathering, and Documenting a Sustainable Claim

    By:
    Peter J. Scalise
    |
    May 1, 2018
    In 1981, the U.S. economy was in a recession, and research-and-development jobs were declining throughout the country. In response, Congress passed the Economic Recovery Tax Act of 1981, which included the Research and Development Tax Credit Program (hereinafter “RTCP” or “RTC”), enacted into the IRC. 

  • The New Qualified Business Income Deduction Under IRC Section 199A

    By:
    Ellen Seiler Brody, Esq., and Vivek A. Chandrasekhar, Esq.
    |
    Apr 1, 2018
    Public Law 115-97 (the Act) provided a significant benefit to corporate taxpayers. While the highest marginal corporate tax rate was previously 35%, corporations now face only a flat 21% tax. In an attempt to provide parity for non-corporate taxpayers, the Act introduces a new IRC section 199A, which provides a 20% deduction for qualified business income earned by individuals, trusts, and estates. 
  • Relationship Capital: How to Evaluate Personal Goodwill Prior to Selling a Closely-Held Business

    By:
    Ladidas Lumpkins, CPA, JD, LLM (Taxation) and Roman Katz, JD
    |
    Mar 1, 2018
    How do you evaluate the financial power of relationships? An iconic scene from the movie The Devil Wears Prada offers great insight, particularly when powerful fashion editor Miranda Priestly recounts how she persuaded the magazine’s publisher to pass over a younger challenger for the job.
  • Understanding Unrelated Business Income Tax

    By:
    Israel Tannenbaum
    |
    Mar 1, 2018

    Facing increased competition for donor dollars and a growing charitable base, many tax-exempt organizations have set their sights on income diversification. As part of this quest for alternative revenue streams, non-profits are expanding into businesses traditionally dominated by taxable entities.  While this can be a boon to an organization’s resources, it can potentially subject tax-exempt entities to reporting and paying taxes, the most common of which is the tax on unrelated business income. 

 

 
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