Oregon Rules That Dividends and Gains From the Sale of Subsidiaries Are Not Taxable

Although income from an intangible asset may meet the state’s definition of apportionable “business income,” the asset from which such income is derived must still satisfy the Constitutional requirement for apportionment by serving an operational function within the business. By: Jess Johannesen, CPA, State and Local Tax Senior Manager at Aprio The Oregon Tax Court…

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New International Tax Reporting Required with Partnership and S Corporation Tax Returns

In recent years, the IRS has continued to emphasize U.S. international tax reporting as a high enforcement priority.  U.S. taxpayers with outbound activities in other countries are subject to strict U.S. international tax reporting requirements that require certain disclosures to the IRS.  Substantial penalties apply for noncompliance.  Many of the international tax reporting forms are…

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S Corporation Acquisitions with Foreign Target Corporations

There are a couple of different structuring options for the acquisition of an S corporation. A buyer that is a corporation will consider making an election that will recharacterize a sale of S corporation stock as a sale of assets. This election creates a fiction of an asset sale that can provide a substantial tax benefit…

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The Pulse – What’s happening in the Economy and the Capital Markets : 1/18/21 – 1/22/21

Executive Summary The economy and the markets are continuing their healthy start to the year — recent government data shows that the residential housing market continues to rebound, and high-frequency data also shows recovery. At the same time, the markets are shifting toward technology, which is a beneficiary of the slower-than-expected pace of global vaccinations.…

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Maryland’s Pass-through Entity Tax Election: Is There a Benefit for Restaurants, Hotels, Distributors and Retailers?

Recent IRS and Maryland publications have provided additional guidance and clarification on Maryland’s pass-through entity (PTE) tax election. The election is a response to the Tax Cuts and Jobs Act (TCJA) of 2017 limiting the state and local tax (SALT) deduction to $10,000 and decreasing many taxpayers’ total itemized deductions. After dispelling some of the…

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