FGMK Tax Alert – Summary of Key Tax Provisions in President’s FY2023 Budget
On March 28, 2022, President Biden released his FY2023 budget (the “FY2023 Budget”), and the U.S. Treasury released the so-called “Green Book,” which provides details related to the revenue provisions in the FY2023 Budget. This FGMK Tax Alert provides a summary of the salient tax provisions offered under this proposal. Increased Tax Rates, New …
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U.S. International Tax 2022 Health Check
While significant current developments in international tax are evolving (potential U.S. tax reform, adoption of OECD’s Pillar One and Two, recently issued foreign tax credit regulations, etc.) companies and individuals with multi-national operations or interests should assess how they are positioned globally from a tax efficiency standpoint for what might be coming in potential tax …
Tax Treatment of Carried Interests: Comparing Carried Interests to Capital Interests, 83(b) Elections, and Issues with the New Three-year Rule
Part I: Capital Interests vs. Carried Interests What is a carried interest? A carried interest (also referred to as a profits interest) is a typical piece of the compensation package for managers of private equity funds.[1] Many private equity funds purchase businesses, operate them for a short period, and then sell them for …
The Cash Killer: Excess Inventory
The Census Bureau’s Monthly Report on Manufacturers’ Shipments, Inventories, and Orders for June 2019 showed a 0.3 percent increase in inventories of manufactured durable goods to $425.8 billion. During that same time, shipments were up 1.4 percent to $258.2 billion. The resulting difference between inventories and shipments was $167.6 billion (39% of total inventory). This, …
Catch Me If You Can! Calculating The True Costs Of Manufacturing A Product
There are various cost accounting techniques used to measure the cost of a product. The three most common methods are job costing, process costing, and activity-based costing. Job Costing is most commonly used when costs can be attributed to specific units or groups of units, as is often the case for manufacturing environments producing …
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Tax-Exempt Entities Should Exercise Caution Before Investing in Real Estate Partnerships
Why is there a tax on unrelated business income for exempt entities? Congress does not want a tax-exempt entity to use its tax exemption to put for-profit companies out of business. If a tax-exempt entity is doing something that a for-profit company does and competing with for-profit companies, it should not get the benefit …
Illinois Secure Choice Program: It Is Here And It May Affect Employers Already In 2019
Illinois has successfully launched the Illinois Secure Choice Program. The Illinois Secure Choice Savings Program Act (820 ILCS 80/85) requires affected employers to either have a retirement plan in place for employees or to register for the Illinois Secure Choice Program. Failure to comply will result in such employer paying a fine of $250 per …
Cloud Computing And Chicago’s Personal Property Lease Transaction Tax
Cloud computing refers to a collection of tools and applications offered through the internet, accessed from anywhere, and provided through any one of three service models, including Software as a Service (“SaaS”), Platform as a Service (“PaaS”), and Infrastructure as a Service (“IaaS”). The treatment of cloud computing transactions for state and local sales and …
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Treasury Provides Additional Qualified Opportunity Zone Guidance
On April 17, 2019, United States Department of Treasury (“Treasury”) released the highly anticipated second round of proposed regulations pertaining to Qualified Opportunity Zones (the “Proposed Regulations”). While still leaving certain questions open, the Proposed Regulations provide much needed guidance and clarity on a number of major outstanding questions. The Proposed Regulations cover a wide …
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U.S. Residency – Overview and Procedures
The general rule is that only U.S. Persons are subject to tax on their worldwide income on their respective Form 1040. Non-U.S. Persons, in contrast, are only subject to tax on their U.S. source income, and file Form 1040NR. Let us review the distinction and thresholds that determine whether someone is considered a U.S. Person, …