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California Seeks to Limit Net Operating Losses

From the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), California was one of the handful of states that did not conform to a number of provisions in the law. Most notably, the state continued to allow taxpayers to take full advantage of the net operating loss (NOL) deduction and ignore 80% ...

Private Equity – Tax Reporting Requirements and Considerations

When determining their tax reporting and compliance requirements, there are many factors that private equity firms must consider. Private equity firms are setup as tiered structures, generally with four levels: the portfolio investment level, the investor level, the fund level, and the fund manager ...

United States Income Tax Treaties That Meet the Requirements of Section 1(h)(11)(C)(i)(II)

IRS released Notice 2024-11 on December 28, 2023, updating the list of countries with tax treaties meeting Section 1(h)(11)(C)(i)(II) criteria. Under section 1(h)(11) (qualified dividends), a dividend paid to an individual shareholder from either a domestic corporation or a "qualified foreign ...

A Quick Guide for Accounting Method Change

Accounting methods, whether general (like cash or accrual) or specialized (e.g., long-term contract methods), are pivotal for financial reporting. This guide provides a quick reference for the process of changing accounting methods, encompassing IRS consent, Form 3115 submission, and key ...

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