Choice-of-Entity Decisions Under the New Tax Act

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ISBN 13 :
Total Pages : 8 pages
Book Rating : 4.:/5 (13 download)

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Book Synopsis Choice-of-Entity Decisions Under the New Tax Act by : Bradley T. Borden

Download or read book Choice-of-Entity Decisions Under the New Tax Act written by Bradley T. Borden and published by . This book was released on 2018 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt: This short article illustrates how the 2017 Tax Cuts and Jobs Act taxes $500,000 of ordinary income depending upon whether it is earned by a corporation, a passthrough as qualified business income (QBI), or a passthrough as income from a specified service trade or business (SSTB). The article shows that the effective tax rate on QBI, which qualifies for the 20% QBI deduction, will rival the effective tax rate on income earned and distributed by a corporation. Tax on income from an SSBT will be higher than the same income from a QBI, but, if the owner of the SSBT plans to withdraw most of the earnings from the SSTB, a passthrough entity will often provide a lower effective tax rate than a corporation. The choice between passthrough entity and corporation will be affected by the amount of income that the owner withdraws from the business and the amount of income the business generates. Lower-income SSTBs may qualify for the QBI deduction, reducing the effective tax rate on passthrough income, and enhancing the attractiveness of the passthrough entity. Conversely, the effective tax rate on passthrough income increases as business income moves into the millions of dollars, triggering the application of the highest marginal rates. The choice-of-entity preference for businesses with that level of income may move toward corporations, especially if the owners do not withdraw all of the business's income.

Tax Cuts and Jobs Act Impact

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Publisher : CCH Incorporated
ISBN 13 : 9780808049906
Total Pages : 0 pages
Book Rating : 4.0/5 (499 download)

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Book Synopsis Tax Cuts and Jobs Act Impact by : Robert Watt Jamison

Download or read book Tax Cuts and Jobs Act Impact written by Robert Watt Jamison and published by CCH Incorporated. This book was released on 2018-04-30 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Tax Cuts and Jobs Act is considered the most sweeping tax law change in decades, and, for many individuals and businesses, the massive and complex changes will have a profound impact. This includes the impact on choice of entity decisions, affected by how C corporations and pass-through entities will be taxed under the new Act. These drastic changes may cause many businesses to reconsider their current entity structure. The all-new CCH(R) AnswerConnect: Tax Cuts and Jobs Act Impact - Guide to Choice of Entity discusses the factors involved in choosing a form of business entity. The options available include being taxed as a C Corporation, where the entity is responsible for paying taxes, or being taxed as a pass-through entity, where the individual owner of the entity is responsible for paying the tax. With this authoritative guide you will gain a more solid understanding of the tax implications of choice of entity, the advantages and disadvantages of changing entities and the factors to consider before making that decision. The CCH Answer Connect Guide on Choice of Entity discusses the factors involved in choosing a form of business entioty after the Tax Cuts and Jobs Act.. Basically the choice is either a C Corporation where the entity is responsible for paying the taxes or a Pass-Through Entity (S Corporation or Partnership) where the individual owner of the entity is responsible for paying the tax. Factors to be considered in making this choice include, among others, the number and types of owners, the jurisdctions in which the business operates, the type of business and industry and the desired tax treatment.. Many businesses may feel that the tax treatment of a pass-through is more favorable because pass-throughs are not subject to a double tax and pass-throughs are able to utilize the capital gain tax rate on the eventual sale of the assets of the business. Hiowever, the changes made to the corporate tax law by the TCJA, such as the reduced tax rate of 21% may make the C Corporation entity more attractive.

Income-Based Effective Tax Rates and Choice-of-Entity Considerations Under the 2017 Tax Act

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Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.:/5 (13 download)

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Book Synopsis Income-Based Effective Tax Rates and Choice-of-Entity Considerations Under the 2017 Tax Act by : Bradley T. Borden

Download or read book Income-Based Effective Tax Rates and Choice-of-Entity Considerations Under the 2017 Tax Act written by Bradley T. Borden and published by . This book was released on 2018 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Article uses a simple model to graphically present the effective tax rates at various income levels for small businesses under the Tax Cuts and Jobs Act of 2017 (TCJA) and compares them to effective tax rates at various income levels for small business prior to the TCJA. The graphical presentation reveals that the various tax rates under the TCJA complicate choice-of-entity analyses and undermine general rule-of-thumb concepts that drove choice-of-entity decisions prior to the TCJA. Under TCJA, choice-of-entity preferences will likely be highly situational and may feature combinations of various entities. Using a typical business situation, the Article illustrates how different types of entity can cause the effective tax rate on business income at the $1,000,000 level to vary from 21.36% to 34.60%. The most favorable effective rate results from an entity structure that combines a C corporation and passthrough entity. Rate variations based upon entity combinations portend subtle, carefully calculated, shifts in choice-of-entity actions following JCTA.

Choice of Entity

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ISBN 13 : 9781633591288
Total Pages : pages
Book Rating : 4.5/5 (912 download)

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Book Synopsis Choice of Entity by : James M. Kehl

Download or read book Choice of Entity written by James M. Kehl and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... discusses federal income tax and other considerations pertinent in choosing the most advantageous legal form for conducting business and investment activities. This Portfolio, in conjunction with 701 T.M., Choice of Entity: Operational Issues, provides a summary perspective on the various legal forms of business enterprises and their relative advantages and disadvantages. These forms primarily include the sole proprietorship, a general partnership, a limited partnership, a regular corporation, an S corporation, a limited liability company, and a trust. A variety of other specialized entities have unique treatment as specified under the Internal Revenue Code, however, and those entities are also examined in this Portfolio. While the "check-the-box regulations" provided greater flexibility and removed impediments concerning the choice of an entity, the decision as to the most advantageous entity through which to conduct a business can be complicated and is impacted by various business and tax factors"--Page iii.

Explaining Choice-of-Entity Decisions by Silicon Valley Start-Ups

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ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (137 download)

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Book Synopsis Explaining Choice-of-Entity Decisions by Silicon Valley Start-Ups by : Gregg D. Polsky

Download or read book Explaining Choice-of-Entity Decisions by Silicon Valley Start-Ups written by Gregg D. Polsky and published by . This book was released on 2019 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Perhaps the most fundamental role of a business tax advisor is to recommend the optimal entity choice for nascent business enterprises. Nevertheless, even in 2018, the choice-of-entity analysis remains highly muddled. Most tax practitioners across the United States consistently recommend flow-through entities, such as LLCs and S corporations, to their clients. In contrast, a discrete group of highly sophisticated tax professionals, those who advise start-ups in Silicon Valley and other hotbeds of start-up activity, prefer C corporations. Prior commentary has described and tried to explain this paradox without finding an adequate explanation. These commentators have noted a host of superficially plausible explanations, all of which they ultimately conclude are not wholly persuasive. The puzzle therefore remains. This article attempts to finally solve the puzzle by examining two factors that have been either vastly underappreciated or completely ignored in the existing literature. First, while previous commentators have briefly noted that flow-through structures are more complex and administratively burdensome, they did not fully appreciate the source, nature, and extent of these problems. In the unique start-up context, the complications of flow-through structures are exponentially more problematic, to the point where widespread adoption of flow-throughs is practically infeasible. Second, the literature has not appreciated the effect of perplexing, yet pervasive, tax asset valuation problems in the public company context. The conventional wisdom is that tax assets are ignored or severely undervalued in public company stock valuations. In theory, the most significant theoretical benefit of flow-through status for start-ups is that it can result in the creation of valuable tax assets upon exit. However, the conventional wisdom makes this moot when the exit is through an initial public offering or sale to a public company, which are the desired types of exits for Silicon Valley start-ups. Thus, the most significant benefit of using a flow-through (at least in theory) is eliminated because of the tax asset pricing problem. Accordingly, while the costs of flow-through structures are far larger than have been appreciated, the benefits of these structures are much smaller than they appear.

Partnership Taxation

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Publisher : Aspen Publishing
ISBN 13 : 1543827276
Total Pages : 464 pages
Book Rating : 4.5/5 (438 download)

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Book Synopsis Partnership Taxation by : George K. Yin

Download or read book Partnership Taxation written by George K. Yin and published by Aspen Publishing. This book was released on 2020-09-15 with total page 464 pages. Available in PDF, EPUB and Kindle. Book excerpt: The purchase of this ebook edition does not entitle you to receive access to the Connected eBook on CasebookConnect. You will need to purchase a new print book to get access to the full experience including: lifetime access to the online ebook with highlight, annotation, and search capabilities, plus an outline tool and other helpful resources. In this concise, tightly edited casebook, George K. Yin and Karen C. Burke emphasize core principles and policies to help students understand the overall structure and coherence of partnership taxation. The book’s organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses, by offering a “building-block” approach that progresses from basic to complex partnership transactions. By emphasizing the policy choices that lend structure and coherence to the law, Partnership Taxation facilitates an understanding of the overarching principles of partnership tax. Students learn the law from basic source material—the Code and regulations—as well as tightly edited cases and other guidance. Many problems, questions, and explanations supplement the presentation to guide students through the challenging material. New to the Fourth Edition: The Fourth Edition reflects developments through February 2020, including: Expanded discussion of choice-of-entity issues in light of significant changes introduced by the 2017 tax legislation, including the 21% corporate tax rate and the section 199A passthrough deduction Revised regulations concerning allocation of partnership liabilities, including disregarded bottom-dollar payment obligations The temporary expensing deduction under section 168(k), as well as new limitations on business interest deductions and excess business losses New section 1061 imposing a three-year capital gain holding period for service partners receiving partnership interests in certain investment partnerships The revised definition of a “substantial built-in loss” under section 743(b) and repeal of the technical termination rule under section 708 Professors and students will benefit from: Approach: This book emphasizes core principles and policies to help students understand the overall structure and coherence of partnership taxation. Organization: The organizational structure bridges concepts learned in the introductory income tax course and those presented in advanced tax courses; “building-block” approach progresses from basic to complex partnership transactions. Depth: By providing in-depth coverage while avoiding unnecessary detail, the revised Fourth Edition facilitates mastery of the material and prepares students to think rigorously and creatively about the kinds of problems they will encounter as practitioners of tax and business law. Lenny faces are short character strings that describe emotions and make your text stand out.

Choice of Entity

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ISBN 13 : 9781633594449
Total Pages : 0 pages
Book Rating : 4.5/5 (944 download)

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Book Synopsis Choice of Entity by : Leila Vaughan

Download or read book Choice of Entity written by Leila Vaughan and published by . This book was released on with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... discusses federal income tax and other considerations relevant to choosing and operating the most advantageous legal form for conducting business and investment activities. This Portfolio provides a summary perspective on the various legal forms of business enterprises and their relative advantages and disadvantages. These forms primarily include the sole proprietorship, a general partnership, a limited partnership, a regular corporation, an S corporation, a limited liability company, and a trust. A variety of other specialized entities have unique treatment as specified under the Internal Revenue Code, however, and those entities are also examined in this Portfolio. While the "check-the-box regulations" provide additional flexibility, the decision as to the most advantageous entity through which to conduct a business can be complicated and is impacted by various business and tax factors. This Portfolio examines possible legal and business structures, outlines the main advantages and disadvantages of each (from primarily a tax perspective) and analyzes the federal income tax rules applicable throughout the life cycles of these entities. The Portfolio provides an expansive discussion of the various entity classification rules under the "check-the-box" regulations and a comparison of the income tax rules applicable throughout the life cycles of the various entities. This Portfolio also examines relevant state law and other organizational issues that impact choice of entity."--Page iii.

Introduction to the Taxation of Business Organizations and Choice of Entity

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Publisher :
ISBN 13 : 9781531004224
Total Pages : 716 pages
Book Rating : 4.0/5 (42 download)

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Book Synopsis Introduction to the Taxation of Business Organizations and Choice of Entity by : Michael K. Friel

Download or read book Introduction to the Taxation of Business Organizations and Choice of Entity written by Michael K. Friel and published by . This book was released on 2018-07 with total page 716 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Egan on Entities

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Publisher :
ISBN 13 : 9781522194101
Total Pages : 859 pages
Book Rating : 4.1/5 (941 download)

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Book Synopsis Egan on Entities by : Byron F. Egan

Download or read book Egan on Entities written by Byron F. Egan and published by . This book was released on 2020 with total page 859 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of Corporate Taxation

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Publisher : West Publishing Company
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Fundamentals of Corporate Taxation by : Stephen A. Lind

Download or read book Fundamentals of Corporate Taxation written by Stephen A. Lind and published by West Publishing Company. This book was released on 1997 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

LLC Or Corporation?

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Publisher : NOLO
ISBN 13 : 141330558X
Total Pages : 268 pages
Book Rating : 4.4/5 (133 download)

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Book Synopsis LLC Or Corporation? by : Anthony Mancuso

Download or read book LLC Or Corporation? written by Anthony Mancuso and published by NOLO. This book was released on 2006 with total page 268 pages. Available in PDF, EPUB and Kindle. Book excerpt: As businesses grow, owners find themselves wondering if they should upgrade their legal structure to something more sophisticated, such as a limited liability company or a corporation. The question is, "Which one?" The answer isn't always clear -- but because your choice will affect the legal and tax status of your business, it's the most important question you'll answer. LLC or Corporation? will help you make the right choice with plain-English explanations of: • the basics of business entities • how each business entity protects you from personal liability • profits, losses and tax treatment • converting from one type of business entity to another • what to do if you conduct business out of state Making the right choice will affect your bottom line in many ways -- from what you pay for taxes, to your ability to seek money from investors. The book also provides conversion and formation scenarios that provide a real-world look at all the options available to you. This book is not really just for those starting a business. It's actually aimed at anyone already in business who wants to determine if they should convert—for example—from a partnership to an LLC or from a sole proprietorship to a corporation. The 2nd edition includes the latest laws regarding business structures, as well as new tips on taxes.

Farmer's Tax Guide

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ISBN 13 :
Total Pages : 120 pages
Book Rating : 4.:/5 (3 download)

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Book Synopsis Farmer's Tax Guide by :

Download or read book Farmer's Tax Guide written by and published by . This book was released on 1992 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Selecting the Right Form of Business

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ISBN 13 :
Total Pages : 336 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Selecting the Right Form of Business by : Bruce D. Bernard

Download or read book Selecting the Right Form of Business written by Bruce D. Bernard and published by . This book was released on 1997 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains factors surrounding business entity decisions, for professional advisors and business owners starting a new company, adding a new business venture, or changing the classification status of an ongoing business. Details different forms of business such as partnership and trust, and explains income tax on business profits, sales of assets, compensation issues, and determining tax status. Includes a business entity comparison chart and a summary of state LCC legislation as of January 1996. Annotation copyrighted by Book News, Inc., Portland, OR

Fundamentals of Partnership Taxation

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ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Fundamentals of Partnership Taxation by : Stephen A. Lind

Download or read book Fundamentals of Partnership Taxation written by Stephen A. Lind and published by . This book was released on 2002 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:

U.S. Tax Guide for Aliens

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Publisher :
ISBN 13 :
Total Pages : 52 pages
Book Rating : 4.:/5 (3 download)

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Book Synopsis U.S. Tax Guide for Aliens by :

Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:

United States Code

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ISBN 13 :
Total Pages : 1506 pages
Book Rating : 4.:/5 (327 download)

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Book Synopsis United States Code by : United States

Download or read book United States Code written by United States and published by . This book was released on 2013 with total page 1506 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The United States Code is the official codification of the general and permanent laws of the United States of America. The Code was first published in 1926, and a new edition of the code has been published every six years since 1934. The 2012 edition of the Code incorporates laws enacted through the One Hundred Twelfth Congress, Second Session, the last of which was signed by the President on January 15, 2013. It does not include laws of the One Hundred Thirteenth Congress, First Session, enacted between January 2, 2013, the date it convened, and January 15, 2013. By statutory authority this edition may be cited "U.S.C. 2012 ed." As adopted in 1926, the Code established prima facie the general and permanent laws of the United States. The underlying statutes reprinted in the Code remained in effect and controlled over the Code in case of any discrepancy. In 1947, Congress began enacting individual titles of the Code into positive law. When a title is enacted into positive law, the underlying statutes are repealed and the title then becomes legal evidence of the law. Currently, 26 of the 51 titles in the Code have been so enacted. These are identified in the table of titles near the beginning of each volume. The Law Revision Counsel of the House of Representatives continues to prepare legislation pursuant to 2 U.S.C. 285b to enact the remainder of the Code, on a title-by-title basis, into positive law. The 2012 edition of the Code was prepared and published under the supervision of Ralph V. Seep, Law Revision Counsel. Grateful acknowledgment is made of the contributions by all who helped in this work, particularly the staffs of the Office of the Law Revision Counsel and the Government Printing Office"--Preface.

Model Rules of Professional Conduct

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Publisher : American Bar Association
ISBN 13 : 9781590318737
Total Pages : 216 pages
Book Rating : 4.3/5 (187 download)

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Book Synopsis Model Rules of Professional Conduct by : American Bar Association. House of Delegates

Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.