John G. Hodnette

PTET Election Under The OBBBA

As discussed in New North Carolina PTE Tax Can Reduce Federal Income Taxes (December 14, 2022), the pass-through entity tax (the “PTET”) elections enacted…

S Corporation F Reorganizations Under Rev. Rul. 2008-18

An F reorganization, as discussed in The Basics of F Reorganizations, is a tax-free “mere change in identity, form, or place of organization of one…

Qualified Trade or Business Under Section 1202

and Savannah Rankich The general rules for qualified small business stock (“QSBS”) were discussed previously in “Gain Exclusion for Section 1202…

Section 453 Trap for S Corporation Asset Sales

In my prior post, Installment Sale Notes Owned by S Corporations, I discussed sales of S corporation assets in exchange for a promissory note, invoking the…

199A Deduction for Real Estate Rental Businesses

Section 199A, as discussed in my prior blog post Section 199A Pass-Through Deduction and the Magic Number, provides for a deduction generally equal to the…

Basics of 338(h)(10) Elections

Section 338(h)(10) allows a buyer and seller in a qualified stock purchase to elect jointly for the sale of target stock to be treated for tax purposes as a…

Exclusions to the Net Investment Income Tax

Since its enactment on March 30, 2010, in connection with the Affordable Care Act, Section 1411 has assessed an additional 3.8% income tax on individuals,…

Installment Sale Notes Owned by S Corporations

When an S corporation sells its assets, often part of the purchase price is paid via a promissory note issued by the buyer. These promissory notes are part of…

Unreimbursed Expenses of Employees and Partners

The 2017 Tax Cuts and Jobs Act included Section 67(h), which eliminated miscellaneous itemized deductions for tax years beginning after December 31, 2017. The…

Publicly Traded Partnerships

Section 7704 provides a partnership is a publicly traded partnership if interests in the partnership are (1) traded on an established securities market or (2)…