New Regulations Provide Clarity About “Specified Service Trade or Business” Categories Under Section 199A
Under IRC § 199A, some businesses that are not C corporations can claim an income tax deduction equal to 20% of their combined qualified business income, subject to certain adjustments and limitations. Read More ›
2019 Update – How to Deal with Section 1061's Three Year Holding Period Requirement for Carried Interests
Hedge fund, private equity and real estate professionals value the carried interest because it allows them to be compensated for their services at long-term capital gains rates. In a prior article, we discussed the impact of the new IRC § 1061 and provided a summary of its rules. This article provides an update on the status of IRC § 1061 and discusses methods for avoiding its application. Read More ›
IRS Opens Determination Letter Program for Cash Balance Plans, Pension Equity Plans, and Certain Merged Plans
In 2017, the IRS eliminated the ability of sponsors of individually-designed qualified retirement plans to apply for favorable determination letters other than when a plan is first adopted or is terminated. Read More ›
Despite being a practice area separate and distinct from “family law,” estate planning techniques and strategies adapt not only to changes in tax law but also to the changing societal tides of what makes up a family. Read More ›
Why are tax opinions especially relevant today? Recent changes in the tax laws have left taxpayers and return preparers grappling with challenging tax planning and return position issues. Read More ›
Kentucky Issues New Tax Regulations – Part II: The Importance of Tax Regulations and its Critical Role After Kentucky's Recent Tax Reform
As discussed in my previous blog post: Kentucky Issues New Tax Regulations - Part 1, Regulations have a critical role in the world of tax and can be both helpful and harmful to taxpayers in several instances. The importance of Regulations is even more evident after there has been tax reform efforts at the Federal, state and/or local levels. Read More ›
The Kentucky Supreme Court, in Department of Revenue v. Mark F. Sommer, upheld all lower court decisions requiring the Department of Revenue (DOR) to make its redacted final rulings publicly available. The Court ruled that the state DOR took an “unreasonable and overly broad view” of public records statutes and later denied the department’s request for appeal. Read More ›
We recently published an article on our website (which was further published by Law360 and Lexology) addressing tax and business aspects of structuring equity rollovers in M&A transactions involving private equity buyers. Read More ›
Are You Withholding Too Much on Nonqualified Deferred Compensation?
If you have a nonqualified deferred compensation plan for select employees, you are probably aware that benefit payments under a properly structured plan are generally not taxable for income tax purposes until the payments are received by the employee. Read More ›
As a part of the generational legislation on Kentucky tax passed last April via 2018 HB 486, the General Assembly for the first time in history enacted formal, mandatory unitary combined reporting (MUCR) as a required method of compliance for purposes of the Kentucky corporation income tax. Read More ›
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J. Aaron Byrd is FBT’s Estate Planning Team leader and counsels on probate, trust administration, business succession, and asset protection planning, as well as gift, wealth transfer and generation-skipping taxation issues.