Category Archives: Tax & Estate

Treatise Update! The Corporate Tax Practice Series

We have recently updated our treatise The Corporate Tax Practice Series.

With contributions from more than 435 of the world’s leading tax practitioners, including former Internal Revenue Service and Department of Treasury officials, this 31-volume set is the definitive resource on corporate tax.

The 2017 edition of The Corporate Tax Practice Series contains 100 articles that have been updated to reflect the latest developments in topics ranging from LLC incentive compensation to modifying debt and its consequences. We’ve also added 31 new articles that have not
previously appeared in the series that tackle issues including:

• A financial and income tax analysis of earnouts
• S corporation acquisition techniques
• Misclassification of employees and Section 530 relief
• Significant modification of debt instruments

The updated treatise is available on PLI PLUS, our research database.  If you’d like to order a print copy, please email libraryrelations@pli.edu or call 877.900.5291.

New Publication! Business-Related Provisions of the 2017 Tax Cuts and Jobs Act

PLI has recently made available a new publication, Business-Related Provisions of the 2017 Tax Cuts and Jobs Act.

This Special Alert discusses the impact of many of the complex provisions of the 2017 Tax Cuts and Jobs Act (“TCAJA”) on domestic and international business operations of C corporations, S corporations, and partnerships. It is organized in ten sections and covers:

  1. Introduction
  2. The individual “Rate Structure Changes” for both ordinary income and capital gains
  3. The corporate rate structure changes, including the individual tax on dividends and the dividends received deduction
  4. New Section 199A, which provides for a deduction for certain flow-through business income of sole proprietorships, partnerships, and S corporations
  5. A “First Take” on the impact of the TCAJA on the choice of form decision for domestic operations: C corporation, or flow-through entity
  6. The new limitation on the deduction for business interest
  7. The treatment under the TCAJA of carried interest, that is, profits interest earned by certain hedge fund and private equity managers
  8. Several significant changes impacting both individuals and corporations: (1) the depreciation rules, (2) the Section 179 deduction, (3) changes to the net operating loss deduction, (4) the limitation on excess business losses of an individual, and (5) changes to the like kind exchange provision, Section 1031
  9. Several changes in the international tax arena, including (1) the adoption of a territorial system, (2) the tax on the elimination of the deferral benefit, (3) the taxation of foreign high return amounts, (4) the anti-base erosion rules, and (5) restrictions on income shifting through transfers of intangibles
  10. A “First Take” on the TCAJA’s impact on the domestic M&A, that is, (1) taxable asset acquisitions, (2) taxable stock acquisitions, and (3) acquisitive reorganizations.

Business-Related Provisions of the 2017 Tax Cuts and Jobs Act is available on PLI PLUS, our online research database.  If you’d like to order a print copy, please email libraryrelations@pli.edu or call 877.900.5291.

Treatise Update! The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms

We have recently updated our Treatise, The Circular 230 Deskbook, which helps tax practitioners comply with complex Circular 230 amendments more easily — and avoid costly penalties and sanctions.

This new version includes the following:
• Revised section 1:2, Chevron Deference, examining SIH Partners
LLLP v. Commissioner, in which the court clarified the distinction
between a legislative rule and an interpretive rule for purposes of
the Administrative Procedure Act.
• New section 4:13.8[D][10], Supervisor’s Approval, explaining that
a section 6751 penalty can be assessed only if it is approved by
the immediate supervisor of the individual making such determination
or such higher-level official as the Secretary may designate.
• Updated Appendix L, IRS Form 706; Appendix M, IRS Schedule M-3
(Form 1120); and Appendix N, IRS Form 2848.

The Circular 230 Deskbook is an essential compliance tool for every tax professional who practices before the IRS.

The updated Treatise is available on PLI PLUS, our online research database.  If you’d like to order a print copy, please email libraryrelations@pli.edu or call 877.900.5291.