John Cunningham

LLCS AS PASS-THROUGH ENTITIES

Almost all single-member LLCs and multi-member LLCs are pass-through entities.  Under the link below is an interesting discussion of pass-through entities by the Brookings institution. Here’s the link:  https://www.brookings.edu/research/9-facts-about-pass-through-businesses/

CHANGES IN US FOREIGN TAX RULES UNDER THE TCAJ ACT

For those of you for whom changes in the above rules are relevant or at least interesting, these changes have been skillfully summarized by Lou Vlahos of the FarrellFritz firm in the post under the following link:  https://www.taxlawforchb.com/2018/01/u-s-taxation-of-foreign-income-after-tax-reform/

POST BY LOU VLAHOS ABOUT IMPACT OF TAX CUTS AND JOBS ACT ON ESTATE TAX

Here is a link to an excellent post by Lou Vlahos about the impact of the Tax Cuts and Jobs Act on the federal estate tax: https://www.taxlawforchb.com/2018/01/the-federal-estate-tax-lives-on-but-where-o-death-is-your-sting/

NEW HAMPSHIRE BUSINESS TAXES

For New Hampshire business lawyers and accountants and others who may be interested: The New Hampshire Department of Revenue Administration has confirmed that for tax periods ending on or after December 31, 2018, the business profits tax rate is decreased to 7.9% (previously 8.2%) and the business enterprise tax rate is decreased to 0.675% (previously […]

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 […]