Search Results

The 2017 Tax Cuts and Jobs Act significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest. Under current law, the manager of an investment fund can receive a “profits interest” (also known as a “carried interest” or a “promoted interes...

Although business-related settlement payments (and attorneys’ fees) are generally tax-deductible, the 2017 Tax Cuts and Jobs Act (the Tax Act) restricts an employer’s ability to obtain tax deductions for settlements of sexual harassment and abuse claims that are subject to nondisclosure agreements. This new deduction limitation applies ...

The benefits of the U.S. 2017 tax reform act (the Act) should be broadly felt by Americans, and businesses large and small will see tax relief. The Act contains elements important for stronger economic growth—a competitive corporate tax rate and a move toward a territorial system of international taxation. At the same time, the House and Sena...

Under prior law, the Internal Revenue Code provided that employers would be allowed deductions for operating privately owned aircraft attributable to business flights. Under the new law, though, expenses attributable to entertainment activities will now be 100 percent non-deductible, whereas in the past they were 50 percent deductible. Other change...

The Tax Cuts and Jobs Act (TCJA) is here to stay and its provisions change the landscape of the private equity world going forward. The decrease in corporate rates coupled with new net operating loss limitations, corporate alternative minimum tax repeal, and accelerated expenditures will directly impact how the value and price modeling of deals are...

The Tax Cuts and Jobs Act will dramatically change how income is taxed for business owners of pass-through entities, such as certain partnerships, limited liability companies, and S corporations. As of January 1, 2018, owners of pass-through entities may deduct up to 20 percent of their “qualified business income” from their taxabl...

Under the current U.S. tax code, there are three critical areas that can help high-net-worth individuals, families, and business owners maximize their wealth planning potential. We frame these areas in the form of corresponding emerging themes—estate tax, income, and charitable planning—and propose actionable strategies. This is just a ...

In a summary of the tax law signed on December 22, 2017, there are still seven individual tax brackets, but the top rate was lowered from 39.6% to 37%. Most of the law's provisions became effective on January 1, 2018, with numerous provisions expiring after 2025. Like most tax laws, it is neither positive nor negative in and of itself; rat...

What does the passage of the Tax Cuts and Jobs Act mean for high-net-worth taxpayers? Comparing the Act to current law, we outline the provisions and focus on the proposals most relevant to high income and high-net-worth taxpayers and businesses.

At more than one thousand pages, the new tax reform package has plenty of both carrots and sticks for U.S. taxpayers. Both the short- and long-term effects of the new legislation on economic growth in the U.S. are uncertain at this point, but changes in the tax code will undoubtedly confer both benefits and penalties on certain segments of the U.S....

An IRS advisory published in late December could prevent individuals from deducting property tax prepayments in 2017. According to the advisory, taxpayers can deduct a property tax prepayment in 2017 depending on whether the tax was both assessed and paid before January 1, 2018. Prepayments of anticipated real property taxes that have not been asse...

Depending on where you live, your philosophy on fiscal policy and what your sources of income are, the Tax Cuts and Jobs Act could be viewed as a gift or a lump of coal. No matter how you see it, there is a short window of time for the ultra high-net-worth individuals and families to plan for its effects.

The Tax Reform and Jobs Act was signed into law on December 22, 2017. A side-by-side comparison between the old law and the new law highlights the key changes, including the difference between the individual rates, deductions, exemptions, and effective dates.

Estate planners have heard the list of complaints surrounding the Subtitle B, Chapter 13 of the IRC, also known as the generation-skipping transfer tax’s (GST) introduction into the Code—it is nonsense, too complicated, and frightening. The naysayers, however, are missing that the GST tax is rich and nuanced in its applications—bu...

On December 19, 2017, the House and then the Senate approved HR 1, the “Tax Cuts and Jobs Act,” which was signed into law on December 22, 2017. The major tax overhaul includes a reduction in tax rates for most individuals, a reduction in the top corporate tax rate from 35% to 21%, and a reduction in the tax rate on individual business i...