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Articles by Robert Pluth
Too Involved to Be ‘Limited’? Self-Employment Tax and Limited Partners
In the latest episode of “Tax Stuff You Should Know,” hosts Bob Pluth and Gene Magidenko unpack the complexities of federal self-employment tax through the lens of the Fifth Circuit’s decision in Sirius Solutions. On The discussion centers on how self-employment taxes apply to limited partners, how limited partners are defined for this purpose, and where the Fifth Circuit’s approach in Sirius Solutions diverges from the US Tax Court’s functional analysis.
Captive Insurance: When The IRS Comes Knocking (Podcast)
ArentFox Schiff are most popular: within Immigration and Real Estate and Construction topic(s) with readers working within the Healthcare, Pharmaceuticals & BioTech and Construction & Engineering industries In the latest episode of "Tax Stuff You Should Know," hosts Bob Pluth and Gene Magidenko unpack the CFM Insurance decision, spotlighting the complexities of captive insurance arrangements and the Internal Revenue Service's (IRS) scrutiny of them.
Unlocking the Power of Profits Interests
On They examine Internal Revenue Service (IRS) guidance on profits interests, including the criteria for non-taxable grants, the complexities introduced by vesting, and the design features to maximize the benefits of this valuable planning tool. The discussion also covers common use cases, potential pitfalls, and the importance of understanding both the tax implications and the flexibility offered by this compensation method.
Navigating S Corporation Pitfalls and Preserving Your Status
Bob and Gene unpack the consequences of the termination of an S election, pinpoint frequent triggers of terminations, and suggest practical strategies to prevent these issues. Their conversation underscores the need for careful planning to maintain S corporation status and outlines solutions for inadvertent terminations and other S corporation maladies.
Profits Interest Stuff You Should Know
Share This Page Email In this episode of Tax Stuff You Should Know, hosts Bob Pluth and Gene Magidenko delve into the complexities of profits interests, a compensation tool for partnerships and limited liability companies (LLCs) taxed as partnerships. On They discuss the differences between profits interests and capital interests, tax implications, and the importance of structuring these interests to comply with Internal Revenue Service guidance.
OBB-BA-Di, Ob-La-Da, Life Goes On, Brah? Life – and Tax Policy – Goes On | ArentFox Schiff
Share This Page Email On July 4, President Donald Trump signed into law P.L. 119-21, the “One Big Beautiful Bill Act” (OBBBA), enacting significant changes to the US tax system.
Tax Stuff You Should Know: The Assignment of Income Doctrine and Charitable Contributions in the Hoensheid Case
On They explore the nuances of tax planning, the importance of timing in charitable contributions, and the Internal Revenue Service’s (IRS) scrutiny of such transactions. The conversation emphasizes the need for proper documentation and planning to avoid potential tax issues. Takeaways Exploring how charitable contributions can raise assignment of income issues if not planned properly.
Unlocking Success: How ESOPs Empower Small Businesses and Employees | JD Supra
Employee Stock Ownership Plans (ESOPs) are unique employee benefit plans designed to invest primarily in the stock of the sponsoring employer. For small businesses, ESOPs can serve as a powerful tool for succession planning and employee engagement. By allowing employees to become partial owners of the company, ESOPs can foster a sense of ownership and commitment among the workforce, potentially leading to increased productivity and loyalty.
Tax Revolution: Come Together for The One, Big, Beautiful Bill
Share This Page Email On May 14, the US House Ways and Means Committee advanced its initial markup version of The One, Big, Beautiful Bill, following 17 hours of a Committee meeting to markup the bill with no changes from the 389-page text that was released on May 12. On The Ways and Means portion is part of a larger budget reconciliation bill that Congressional Republican leadership intends to finalize and send to the President’s desk by July 4.
ArentFox Schiff Represents The Open Food Company
Founded in June 2024 by global food industry veteran and classically trained chef Renee Guilbault, and her uncle, the Emmy and Golden Globe nominated actor (and celebrated TV chef) Harry Hamlin, they are believed to be the first “open-source” food company.
IRS Data Leak Hits Home: Actions for Taxpayers in the Wake of the Littlejohn IRS Data Breach | JD Supra
The Internal Revenue Service (IRS) has begun the process of informing over 70,000 taxpayers that their confidential tax information was leaked in a widespread breach by a former IRS contractor. Those impacted should take steps to protect against identity-theft and related abuses, assess potential damages, and consider legal action.
IRS Data Leak Hits Home: Actions for Taxpayers in the Wake of the Littlejohn IRS Data Breach
On This past January, a former IRS contractor, Charles Littlejohn, was sentenced to five years in prison for illegally accessing and disclosing thousands of federal tax returns and related information between 2018 and 2020 (the Littlejohn Breach). The IRS is now notifying the nearly 70,000 taxpayers whose tax information was compromised in what has been described as the largest IRS breach in recent history.
Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year
Off 1. 2024 Congressional Tax Package On January 16, the chairmen of the Senate Finance Committee and the House Ways and Means Committee introduced the Tax Relief for American Families and Workers Act of 2024, which proposes certain changes to US tax law, including the following: Increasing the maximum refundable amount per child under the child tax credit.
We Can Work It Out: IRS Unveils ERC Voluntary Disclosure Program | JD Supra
As we discussed in our September 25 alert, Everybody’s Got Something to Hide Except Me and My Monkey: IRS Issues Moratorium on Processing New Employee Retention Credit Claims, the Internal Revenue Service (IRS) previously indicated that it was finalizing details for a settlement program for repayments for those who received an improper employee retention credit (ERC) payment. On December 21, 2023, the IRS provided details of this new settlement program (the ERC Voluntary Disclosure Program).
We Can Work It Out: IRS Unveils ERC Voluntary Disclosure Program
Specifically, the IRS has now published the procedures for a taxpayer to file an application to participate in the ERC Voluntary Disclosure Program and publicized the benefits of participating in the ERC Voluntary Disclosure Program. Taxpayers should quickly determine whether they intend to submit an application to participate in the ERC Voluntary Disclosure Program, however, because applications must be submitted by 11:59 pm local time on March 22, 2024.
The US Supreme Court to Rule on the TCJA Transition Tax: Is the Realization Requirement Soon to Be No Moore? | JD Supra
On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under section 965 of the Internal Revenue Code of 1986, referred to in the Moore filings as the “mandatory repatriation tax” or “MRT.” The Transition Tax The Tax Cuts and Jobs Act of 2017 (TCJA) moved the US taxation of foreign corporations toward a participation exemption system.
The US Supreme Court to Rule on the TCJA Transition Tax: Is the Realization Requirement Soon to Be No Moore?
On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under section 965 of the Internal Revenue Code of 1986, referred to in the Moore filings as the “mandatory repatriation tax” or “MRT.” Off The Transition Tax The Tax Cuts and Jobs Act of 2017 (TCJA) moved the US taxation of foreign corporations toward a participation exemption system.
Federal Penalty Relief for Certain 2019 and 2020 Tax Returns Filed on or Before September 30, 2022 | JD Supra
The US Internal Revenue Service (IRS) recently released Notice 2022-36, in which the IRS announced that it is automatically waiving (and automatically abating, refunding, or crediting, as appropriate) penalties for failure to timely file specified tax returns for the 2019 and 2020 tax years that are filed on or before September 30, 2022. Penalties for failure to make a timely payment of the tax due, as well as interest thereon, are not being waived.
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