Nonqualified deferred compensation arrangements are commonplace among executives in the American workforce. These arrangements raise tax timing issues for our cash-basis accounting system. When should the compensation be determined to have been “constructively received” by the worker, and thus subject to taxation? Our policy on the issue was originally too lenient in the wake of…
Tag: IRS
Is the End of Tax-Funded Subsidies for Professional Sports Stadiums Near?
Amidst polarizing protests by figures such as Colin Kaepernick, the National Football League and other professional sports organizations have stood at the center of political discussions surrounding free speech, racial inequality, and the role of social media in government in recent years. Amidst contentious debate, however, a closely related topic of advantages and monetary support…
The Consequences of Eliminating State and Local Tax Deductions: Double Taxation and Tax Controversy
The Trump Administration recently passed a comprehensive tax reform package, which includes restrictions on state and local tax (“SALT”) deductions from federal income returns.1 For the fiscal year 2017, the Internal Revenue Code permits deductions for state, local, and foreign taxes relating to income and property taxes.2 Proponents argue that restriction of the deduction will…
Tax Uncertainty for Businesses After the Regulatory Freeze
President Trump’s new executive leadership is likely to bring increasing uncertainty for businesses in the area of tax law as the Internal Revenue Service (IRS) struggles to make sense of the reach and intent of some of the President’s recent orders on federal rulemaking. In one of his first major acts after taking office, President…
Master Limited Partnerships: Where They Have Been and Where They Are Going
A master limited partnership (“MLP”) is a business that acts like a corporation (meaning it is publicly traded and an investor can buy units of it like it would buy shares of a corporation) but is organized as a partnership—thus not subject to double taxation like a traditional corporation. The first MLP came into existence…