• Tax Court Rules Family Office Is Engaged in a Trade or Business

    12 Jan 2018

    On December 13, 2017, in Lender Management, LLC v. Commissioner, the U.S. Tax Court ruled that a family office, Lender Management, LLC (“Lender Management”), was “carrying on a trade or business” as an investment manager rather than serving as a passive investor and therefore was entitled to deduct expenses under Section 162[1] as opposed to Section 212.

  • Tax Reform Summary for Family Offices

    23 Dec 2017
    On December 20, 2017, Congress passed the “Tax Cut and Jobs Act,” which was signed into law by President Trump on December 22, 2017. With some exceptions, the law’s provisions generally are effective for tax years beginning on or after January 1, 2018, and most of the provisions directly affecting non-corporate taxpayers will expire on December 31, 2025. The Tax Cuts and Jobs Act contains several provisions that may have a significant impact on the operations of family offices, including their investment vehicles.
  • Tax Cuts and Jobs Act: House and Senate Pass Tax Reform Bill

    21 Dec 2017

    On December 20, 2017, the House of Representatives and the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Bill”). This follows the release by the conference committee of the final legislative text on December 15, 2017. The Bill replaces the prior versions of H.R. 1 passed by the House of Representatives (the “House Bill”) on November 16, 2017 and the Senate (the “Senate Bill”) on December 2, 2017. President Trump signed the Bill into law on December 22, 2017. The Bill represents the most significant changes to the US tax code since 1986.

  • Renewable Energy Update: Effect of the Tax Cuts and Jobs Act of 2017

    21 Dec 2017

    On December 19 and 20, 2017, both the House and the Senate passed the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Act”), which is expected to be signed by the President. The House of Representatives had passed an earlier version of H.R. 1 (the “House Bill”) on November 16, 2017 by a vote of 227-206, and the Senate had passed its version of H.R. 1 (the “Senate Bill”) on December 2, 2017 by a vote of 51-49. During the week of December 4, 2017, the House of Representatives and the Senate formed the conference committee to reconcile the differences between the House Bill and the Senate Bill. The Tax Reform Act reflects, with minor changes not relevant to this discussion, the conference committee’s bill, released on December 15, 2017.

  • 2018 Proxy Season – Quick Reference Guide

    7 Dec 2017

    Death, taxes and proxy season. Although it may seem like you just filed your 2017 proxy, the 2018 proxy season is on the horizon. This quick reference guide identifies considerations based on themes from 2017, offers recommendations and resources for the upcoming season and discusses expected future changes in disclosure rules that public companies will want to keep on their radar as proxy preparations begin.

  • House Passes Tax Cuts and Jobs Act: How the Senate Proposal Compares

    17 Nov 2017

    On November 2, 2017, the House Ways and Means Committee (the “House Committee”) released their plan for comprehensive tax reform: the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “House Bill”). Following a week of hearings, the House Committee amended and approved the House Bill by a party-line vote of 24-16 on November 9. On November 16, the House of Representatives passed the House Bill by a vote of 227-205.

  • The Republican Tax Plan and the Revenue-Raising Assault on Employee Compensation

    8 Nov 2017

    On November 2, 2017, the Republican caucus of the House of Representatives unveiled its plan to overhaul the nation’s tax code. In an apparent effort to raise revenue, the “Tax Cuts and Jobs Act”, if adopted, would fundamentally change the way many US employees are compensated. The Ways and Means Committee began its mark-up of the bill on November 6th, and the committee’s first amendment was released that evening. Additional changes are expected. The Senate is expected to introduce its own tax bill this week.

    The following is a summary of the amended bill’s proposed changes to employee compensation, employee-related income deductions and the rules governing retirement savings. As the amended bill progresses, we will provide additional client publications on the bill’s impact on the design and disclosure of employee compensation programs.

  • House Republican Tax Reform Bill Retains and Modifies Energy Credits

    3 Nov 2017

    On November 2, 2017, the House Republicans released their plan for comprehensive tax reform, the “Tax Cuts and Jobs Act of 2017” (H.R. 1) (the “Tax Reform Bill”). Prior to this release, Congressional Republicans and the Trump Administration had provided few concrete details of their tax reform plans, including whether adjustments, if any, would be made to current tax credit regimes for energy investments. As discussed below, the Tax Reform Bill modifies, but keeps in place, the production tax credit (“PTC”) and the investment tax credit (“ITC”) for energy investments. The Tax Reform Bill also reduces tax rates for businesses and individuals, provides for immediate expensing for certain capital expenditures and limits the deduction for interest expense for most businesses. All of these provisions should have an effect on energy investments if the Tax Reform Bill is enacted in its current form. 

  • House Committee on Ways and Means Releases Tax Reform Proposal

    2 Nov 2017
    The House Committee on Ways and Means released today its proposed legislative language (the “House Proposal”) implementing, in large part, the framework for tax reform issued by the so-called “Big Six” on September 27, 2017. This client alert summarizes the key income, estate and gift tax provisions of this proposal.
  • Trump Administration and Congressional Leaders Release Tax Reform Framework

    28 Sep 2017
    On September 27, 2017, the Trump Administration, the House Committee on Ways and Means and the Senate Committee on Finance released their much-anticipated framework for tax reform (the “Framework”). The Framework generally proposes to lower taxes on most businesses and individuals and to simplify the US federal income tax system. The Framework sets forth broad principles for tax reform and leaves numerous important details and decisions to the tax-writing Congressional committees.

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