New IRS Guidance Provides Clarification And Simplified Procedures For S Corporations, Including LLCs, To Address Common Missteps

Revenue Procedure 2022-19 (the “Revenue Procedure”), issued by the IRS, provides clarification and describes simplified procedures that allow S corporations, including limited liability companies (“LLCs”) that have made an S election and their owners, to resolve frequently encountered missteps – often without requesting a time-consuming and costly private letter ruling (“PLR”).

S corporations are subject to many restrictions that can create unintended “foot faults,” resulting in material adverse tax consequences. Many times these issues are […]

By | October 25th, 2022 ||

The California Franchise Tax Board Fails To Follow The Order Of Its Market-Based Sourcing Cascading Rules

In the Appeal of Sheward, 2022-OTA-228P (May 25, 2022), the California Office of Tax Appeals (OTA) held the California Franchise Tax Board (FTB) failed to follow its own market-based sourcing apportionment regulation by prematurely using reasonable approximation to source the income of a multistate unitary business. During the tax year 2017, the taxpayer operated a business providing in-person services as a horse racetrack judge in California and Minnesota but failed to file a California return. […]

By | October 22nd, 2022 ||

US Tax Inflation Increases Exemption Amounts And Opportunities

The Internal Revenue Service (IRS) recently unveiled its inflation adjustments for the 2023 US federal tax year. The thresholds for several key tax provisions are increasing considerably, which is unsurprising given the fast pace of consumer price growth and other relevant measures of inflation. Generally speaking, for high-wealth households with US citizen or domiciled individuals the 2023 adjustment translates into a nearly US$1 million increase in the amount of money an individual can shield […]

By | October 18th, 2022 ||