Paul Gevertzman

Guaranteed payments to partners and payments to retired partners are just two of the tax issues that should be addressed in your partnership (or LLC operating) agreement. Here are the details. https://lnkd.in/eZQK8rjn #partnership #llc #taxlaw

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Pennsylvania provides NOL limitation relief, amends related party “addback” In brief What happened? Budget-related tax legislation enacted in Pennsylvania on July 11 increases the net operating loss (NOL) deduction limitation (from 40% to 80% of taxable income by 2029), provides an election concerning the related party expense addback “subject to tax” exception, and amends provisions regarding the deduction of goodwill for bank shares tax purposes, among other changes.  [S.B. 654, enacted 7/11/24]  Why is it relevant?  The legislation marks the latest chapter in Pennsylvania’s limitations on NOL utilization, which has been subject to litigation and amended multiple times over the years. This legislation increases the current percentage limitation in 10% annual increments but continues the 40% limitation for NOL carryforwards from loss years prior to 2025.  Actions to consider  Taxpayers should consider the need to track NOLs by year and the potential impact of this legislation on their ASC 740 tax provision.  https://lnkd.in/gKpGv_-Q

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TRICK OR TREAT (taxpayers with Massachusetts activity may want to act) - From November 1 to December 30, 2024, the Commonwealth of Massachusetts will waive most penalties for eligible taxpayers who file outstanding returns and pay tax and interest owed for tax periods with returns due by December 31, 2024. This applies to almost all tax types and to current Massachusetts taxpayers, taxpayers under audit, taxpayers desiring to file amended returns and non-filers. Non-filers may be eligible for a three-year lookback period. Please note that taxpayers with existing liabilities may receive a letter from the state. We will be publishing a summary of the program in an Alert on our Frazier & Deeter website soon (https://lnkd.in/dhcqRcdA). Contact me with questions. #massachusetts #MAtaxamnesty #MAtax #Massachusettsamnesty #taxamnesty #tax #taxes #stateandlocaltax #SALT #FDSALT #FrazierDeeter #multistatetax #middlemarket #privateequity #taxcontroversy #audits #taxaudits #amendedreturns #nonfilers #mataxnonfilers

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