John Cunningham

TAX CUTS AND JOBS ACT

I’m in the process of reviewing the Tax Cuts and Jobs Act (the “Act”).  The best source I’ve found thus far for understanding the act as a whole and for obtaining basic explanations of its individual provisions is the KPMG study under this link:  https://home.kpmg.com/content/dam/kpmg/us/pdf/2017/12/tnf-conference-agreement-dec18-2017.pdf   However, if any readers of this post know of any […]

THE 2017 TAX ACT: OTHER “PASS-THROUGH” TAX PROVISIONS

Below is a link to the latest in the series of excellent summaries of the pass-through provisions of the Trump tax reform act by Lou Vlahos of the FarrellFritz law firm: https://www.taxlawforchb.com/2018/01/the-2017-tax-act-other-pass-through-tax-provisions-part-ii/

THE NEW DEDUCTION FOR QUALIFIED BUSINESS INCOME

Under the link below is an excellent explanation of the above new deduction. Here’s the link: https://www.taxlawforchb.com/2017/12/the-new-deduction-for-qualified-business-income-tax-simplification-gone-awry/#

THE TRUMP TAX REFORM ACT AND PASS-THROUGH ENTITIES

Under the link below is a brief but excellent post about the impact of the Trump Act on pass-through entities and their owners. Here’s the link:  http://blog.williamsparker.com/businessandtax/2017/12/18/reform-business-tax-reform/

NEW PROPOSED REGULATIONS UNDER BBA PARTNERSHIP AUDIT RULES

On December 15, 2017, the U.S. Treasury Department issued proposed regs that permit partnerships to “push out” IRS audit adjustments to partners who are themselves partnerships in “tiered” partnerships.  Tiered partnerships are partnerships in which one or more partners in one or more levels of partners are themselves partnerships—i.e., partnerships whose partners are partnerships.  This […]

DEBT VS. EQUITY IN CLOSELY HELD ENTITIES

Under the link below is a superb post from FarrellFritz on the issue of when an investor’s transfer of cash to a closely held entity is debt and when it is equity for federal tax purposes.  In my LLC practice, this issue arises often.  Perhaps also in yours.  In any event, you should know the […]

BBA PARTNERSHIP AUDIT DEVELOPMENTS

On November 15, Treasury officials made the following important public statements relevant to the BBA partnership audit rules: They said that the development and publication of Treasury regs about the partnership audit rules are the Treasury’s top regulatory priority. They strongly implied that the pending BBA proposed regs will be issued as final regs on […]

LLC LIQUIDATIONS

From time to time, LLC lawyers are asked by their clients to handle LLC liquidations.  If the LLCs in question are multi-member LLCs taxable as partnerships, there can be major federal income tax traps in these liquidations.  One such trap is described succinctly but with great clarity in the post by Lou Vlahos of the […]

REMINDER! SEMINAR FOR NH ACCOUNTANTS ON LLC AUDITS

On January 1, 2018, radical and draconian new IRS partnership audit rules will become effective for multi-member LLCs and other entities taxable as partnerships. Any failure to advise clients about the new rules could have disastrous consequences. From 10 AM to noon on Thursday, November 9, 2017, John Cunningham, attorney of counsel to McLane Middleton, […]

SEMINAR FOR NH ACCOUNTANTS ON LLC AUDITS

On January 1, 2018, radical and draconian new IRS partnership audit rules will become effective for multi-member LLCs and other entities taxable as partnerships. Any failure to advise clients about the new rules could have disastrous consequences. From 10 AM to noon on Thursday, November 9, 2017, John Cunningham, attorney of counsel to McLane Middleton, […]