pass-through - The S Corporation Association

The Legal Case for Pass-Through SALT Parity

Last week, Bloomberg published a report that got our attention. Entitled, “IRS May Knock down New York, Connecticut SALT Workarounds,” the article says the IRS is “likely” to issue regulations that invalidate SALT workarounds.

The reference to New York didn’t surprise us. It’s no secret the IRS is targeting the charitable workaround adopted by New York and other states – they already issued guidance last fall throwing sand in the gears of that one. But the pass-through SALT parity bills passed by Connecticut and Wisconsin are entirely different, both legally and politically.

Why can C corporations deduct all …

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admin2019-03-14T16:58:06+00:00March 14, 2019|

199A Pass-Through Deduction Rules Finalized

Treasury issued the final rules on 199A earlier this month. You can read the rules and accompanying guidance here:

You can also read a terrific “how does it all work” review published in Forbes the other day. As the writer notes:

I believe in giving credit where credit is due, and …

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admin2021-08-16T14:02:03+00:00January 30, 2019|

S-Corp Comments on 2704

Monday was the close of the comment period for Treasury Notice 2017-38, and the S Corporation Association joined several other trade groups in submitting our final comments on the pending Section 2704 rules, including our study highlighting the threat these rules pose to family businesses and their employees.

This comment period is the latest in a long saga and we hope it marks the beginning of the end. To recap:

August, 2016 – Treasury issues Notice 2017-38 targeting proposed rules under Section 2704;
November, 2016 – The official comment …

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admin2019-01-31T22:48:48+00:00August 14, 2017|

Tax Reform Statement & Pass Through Taxes

Just in time for the August recess, the House, Senate and the White House released a joint statement yesterday on the status of their tax reform talks and their plans moving forward. You can read the statement here. From our perspective, here are the key points:

“While we have debated the pro-growth benefits of border adjustability, we appreciate that there are many unknowns associated with it and have decided to set this policy aside in order to advance tax reform.”

A primary purpose of the statement was to pivot the tax conversation away from the House Blueprint and the …

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admin2021-08-16T14:02:33+00:00August 1, 2017|

The Tax Foundation Gets it Right (Sort Of)

The Tax Foundation published its annual piece on pass through businesses this week, and as usual, there’s lots of great material in there. To begin, the Foundation updates its numbers on pass through employment and marginal tax rates. As in past years, pass through businesses employ the majority of private sector workers even though they face marginal tax rates that often exceed 50 percent! Talk about shooting yourself in the foot, economically speaking.

Robert Samuelson at the Washington Post noticed. In an op-ed last week, he highlighted some of the key metrics found in the Foundation’s report:

“Here are some …

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admin2019-01-31T22:50:18+00:00January 26, 2017|