cwalizer

Today, the S Corporation Association submitted its formal comments to the IRS on the pending Section 163(j) rules.  Section 163(j) would impose the new, 30 percent cap on interest deductions as part of the Tax Cuts and Jobs Act (TCJA). Under the TCJA, Congress intended to impose a higher cap to start, and then lower the cap in the future, giving affected companies time to prepare for the new policy.  But the rules proposed by the IRS would inexplicably apply the lower, more onerous cap to manufacturers immediately!  This is definitely not what Congress intended and will come as an unwelcome ...

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Board Member and Advisory Committee Chair Tom Nichols represented S-Corp in Tuesday’s IRS hearing on Section 199A. Tom was one of 26 witnesses to testify.  As Tax Notes summarized: Thomas J. Nichols of Meissner, Tierney, Fisher & Nichols SC said when taxpayers have losses from one trade or business and income from another, they are required to aggregate those amounts to determine the deduction amount, even though aggregation isn’t mandated when determining whether Form W-2 wages and basis in property can be combined. Instead, taxpayers must jump through several hoops to determine if they can aggregate those businesses, Nichols added. ...

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Everything has its season, and for tax reform, this is the season of sending comments to Treasury.  This week, the S Corporation Association submitted comments on Treasury’s proposed rules implementing the so-called “toll charge” repatriation tax under Section 965. To recap, one of the selling points of tax reform was the move from a system that taxed all the income of U.S. taxpayers, regardless of where it was earned, with a system that focused primarily on taxing income earned with our borders.  This new territorial approach was supposed to make U.S. businesses more competitive overseas.  Only time will tell whether ...

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The S Corporation Association today submitted comments on Treasury’s proposed rules implementing the new, 20-percent pass-through deduction. S-Corp readers know the 20-percent deduction was designed to preserve rate parity between pass-through businesses and the new, 21-percent rate on S corporations.  But how is the deduction going to be calculated?  How many pass-through businesses will qualify?  Our comments kick off by emphasizing just how important the deduction is to keeping Main Street competitive. As our recent EY study made clear, pass-through businesses receiving the full deduction still will pay an effective tax rate that is 1.3-percent higher than the rate paid ...

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