text:
2017 Tax Reform: Last-minute year-end moves in light of Tax Cuts and Jobs Act
C-Corporation, Corporate Income Tax, Federal Tax Law Updates, Individual Income Tax, Tax Planning
Congress is enacting the biggest tax reform law in thirty years, one that will make fundamental changes in the way you, your family and your business calculate your federal income tax bill, and the amount of federal tax you will pay. Since most of the changes will go into effect next year, there's still a narrow window of time before year-end to soften or avoid the impact of crackdowns and to best position yourself for the tax breaks that may be heading your way. Here's a quick rundown of last-minute moves you should think about making.
Lower tax rates coming. The Tax Cuts and Jobs Act will reduce tax rates for many taxpayers, effective for the 2018 tax year. Additionally, many businesses, including those operated as passthroughs, such as partnerships, may see their tax bills cut.
The general plan of action to take advantage of lower tax rates next year is to defer income into next year. Some possibilities follow:
If you are about to convert a regular IRA to a Roth IRA, postpone your move until next year. That way you'll defer income from the conversion until next year and have it taxed at lower rates.
Earlier this year, you may have already converted a regular IRA to a Roth IRA but now you question the wisdom of that move, as the tax on the conversion will be subject to a lower tax rate next year. You can unwind the conversion to the Roth IRA by doing a recharacterization-making a trustee-to-trustee transfer from the Roth to a regular IRA. This way, the original conversion to a Roth IRA will be cancelled out. But you must complete the recharacterization before year-end. Starting next year, you won't be able to use a recharacterization to unwind a regular-IRA-to-Roth-IRA conversion.
If you run a business that renders services and operates on the cash basis, the income you earn isn't taxed until your clients or patients pay. So if you hold off on billings until next year-or until so late in the year that no payment will likely be received this year-you will likely succeed in deferring income until next year.
If your business is on the accrual basis, deferral of income till next year is difficult but not impossible. For example, you might, with due regard to business considerations, be able to postpone completion of a last-minute job until 2018, or defer deliveries of merchandise until next year (if doing so won't upset your customers). Taking one or more of these steps would postpone your right to payment, and the income from the job or the merchandise, until next year. Keep in mind that the rules in this area are complex and may require a tax professional's input.
The reduction or cancellation of debt generally results in taxable income to the debtor. So if you are planning to make a deal with creditors involving debt reduction, consider postponing action until January to defer any debt cancellation income into 2018.
Disappearing or reduced deductions, larger standard deduction. Beginning next year, the Tax Cuts and Jobs Act suspends or reduces many popular tax deductions in exchange for a larger standard deduction. Here's what you can do about this right now:
Individuals (as opposed to businesses) will only be able to claim an itemized deduction of up to $10,000 ($5,000 for a married taxpayer filing a separate return) for the total of (1) state and local property taxes; and (2) state and local income taxes. To avoid this limitation, pay the last installment of estimated state and local taxes for 2017 no later than Dec. 31, 2017, rather than on the 2018 due date. But don't prepay in 2017 a state income tax bill that will be imposed next year – Congress says such a prepayment won't be deductible in 2017. However, Congress only forbade prepayments for state income taxes, not property taxes, so a prepayment on or before Dec. 31, 2017, of a 2018 property tax installment is apparently OK.
The itemized deduction for charitable contributions won't be chopped. But because most other itemized deductions will be eliminated in exchange for a larger standard deduction (e.g., $24,000 for joint filers), charitable contributions after 2017 may not yield a tax benefit for many because they won't be able to itemize deductions. If you think you will fall in this category, consider accelerating some charitable giving into 2017.
The new law temporarily boosts itemized deductions for medical expenses. For 2017 and 2018 these expenses can be claimed as itemized deductions to the extent they exceed a floor equal to 7.5% of your adjusted gross income (AGI). Before the new law, the floor was 10% of AGI, except for 2017 it was 7.5% of AGI for age-65-or-older taxpayers. But keep in mind that next year many individuals will have to claim the standard deduction because, for post-2017 years, many itemized deductions will be eliminated and the standard deduction will be increased. If you won't be able to itemize deductions after this year, but will be able to do so this year, consider accelerating "discretionary" medical expenses into this year. For example, before the end of the year, get new glasses or contacts, or see if you can squeeze in expensive dental work such as an implant.
Other year-end strategies. Here are some other last minute moves that can save tax dollars in view of the new tax law:
The new law substantially increases the alternative minimum tax (AMT) exemption amount, beginning next year. There may be steps you can take now to take advantage of that increase. For example, the exercise of an incentive stock option (ISO) can result in AMT complications. So, if you hold any ISOs, it may be wise to postpone exercising them until next year. And, for various deductions, e.g., depreciation and the investment interest expense deduction, the deduction will be curtailed if you are subject to the AMT. If the higher 2018 AMT exemption means you won't be subject to the 2018 AMT, it may be worthwhile, via tax elections or postponed transactions, to push such deductions into 2018.
Like-kind exchanges are a popular way to avoid current tax on the appreciation of an asset, but after Dec. 31, 2017, such swaps will be possible only if they involve real estate that isn't held primarily for sale. So if you are considering a like-kind swap of other types of property, do so before year-end. The new law says the old, far more liberal like-kind exchange rules will continue apply to exchanges of personal property if you either dispose of the relinquished property or acquire the replacement property on or before Dec. 31, 2017.
For decades, businesses have been able to deduct 50% of the cost of entertainment directly related to or associated with the active conduct of a business. For example, if you take a client to a nightclub after a business meeting, you can deduct 50% of the cost if strict substantiation requirements are met. But under the new law, for amounts paid or incurred after Dec. 31, 2017, there's no deduction for such expenses. So if you've been thinking of entertaining clients and business associates, do so before year-end.
The new law suspends the deduction for moving expenses after 2017 (except for certain members of the Armed Forces), and also suspends the tax-free reimbursement of employment-related moving expenses. So if you're in the midst of a job-related move, try to incur your deductible moving expenses before year-end, or if the move is connected with a new job and you're getting reimbursed by your new employer, press for a reimbursement to be made to you before year-end.
Under current law, various employee business expenses, e.g., employee home office expenses, are deductible as itemized deductions if those expenses plus certain other expenses exceed 2% of adjusted gross income. The new law suspends the deduction for employee business expenses paid after 2017. So, we should determine whether paying additional employee business expenses in 2017, that you would otherwise pay in 2018, would provide you with an additional 2017 tax benefit. Also, now would be a good time to talk to your employer about changing your compensation arrangement-for example, your employer reimbursing you for the types of employee business expenses that you have been paying yourself up to now, and lowering your salary by an amount that approximates those expenses. In most cases, such reimbursements would not be subject to tax.
Please keep in mind that I've described only some of the year-end moves that should be considered in light of the new tax law. If you would like more details about any aspect of how the new law may affect you, please do not hesitate to call us at (310) 691-5040.
December 21, 2017 /0 Comments/by Joshua Azran
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2017-12-21 12:00:462019-10-01 12:14:052017 Tax Reform: Last-minute year-end moves in light of Tax Cuts and Jobs Act
Accounting Consequences of Legal Business Organization
C-Corporation, Entrepreneur, S-Corporation, Startup
If you are starting a business, one of the first decisions to make is the legal structure of the business. This decision will impact your taxes, liability, and control over the business. You will want to take into consideration the following:
How large do you expect the business to be?
What level of personal liability are you comfortable with?
Do you anticipate much liability in the daily operations of the business?
How much revenue do you project?
How comfortable are you with strict organizational structures?
How do the owner(s) plan to take profits out of the business?
This decision should not be taken lightly. Consult your accountant and attorney for advice before making a final decision. They can help guide you through the implications of how you organize your business. They are also the experts in any relevant state and federal laws.
There are three major categories of legal business structures with variations on each. Here are some of the most common legal structures with the pros and cons of each.
Most small businesses start out as a sole proprietorship. This is when there is only one owner who is also responsible for the day-to-day operations of the business. The owner controls all the assets of the business and takes on all the liability of the business operations. Profits and losses are reported directly on the owner's personal income taxes. In effect, the business and the owner are the same entity legally.
Advantages of Sole Proprietorship
Easiest form of business to set up and dissolve.
Single owner has complete control over the business.
All profits can be re-invested in the business or can be used by the owner.
Disadvantages of Sole Proprietorship
Owner has full liability for business operations. This includes all debts or lawsuits against the business. The owner's personal assets are at risk.
It is harder to raise capital from commercial sources with a management team of one.
Employee benefits can not be deducted from the business income. This includes the owner's health insurance.
Variation of Sole Proprietorship
There is only one type of sole proprietorship.
Partnerships are similar to a sole proprietorship except that this entity includes two or more people who share ownership of the business. The day-to-day management of the business may or may not be divided among the partners. Once again the law looks on the owners and the business as a single entity. An operating agreement should be drawn up by a lawyer and signed by all partners governing how the ownership is divided, profits will be distributed, new partners added, and the business dissolved. The cost for a lawyer to write up a good operating agreement is far less than the litigation that may arise over the life of a business.
Advantages of Partnerships
They are still easy to establish, but you should have a professionally written operating agreement.
Liability is spread over several owners.
All profits can be re-invested or flow directly to the owners.
It is easier to get capital from traditional sources including banks.
Disadvantages of Partnerships
All the partners are liable for the debt and lawsuits of the business. The partners' personal assets are at risk.
Profits and decision-making is shared if conflict arises.
Employee benefits can not be deducted from the business income. This includes health insurance.
Variations of Partnerships
General Partners — Members of the ownership team are responsible for day-to-day management, associated liability, and share of profits. Sometimes they are called active partners.
Limited Partners (LLP) — Members of the ownership team only have liability up to their investment and generally have limited input into the day-to-day operations of the business. Sometimes they are called silent partners.
A corporation is registered with the state where the company resides. Legally it is a unique entity from the owners. The taxes are paid by the corporation and it can be sued or enter into contractual agreements. A corporation is owned by shareholders who elect a board of directors to manage the day-to-day business decisions. A lawyer should draw up the ownership agreements.
Advantages of Corporations
Shareholders have limited liability for the corporation's debts and liabilities.
Shareholders can only be held accountable for their investment in the stock of the business.
Easier to raise capital through the sale of stock or through commercial means.
Employee benefits can be deducted from the corporation's profits for taxes.
Disadvantages of Corporations
More difficult to form than a partnership, however most states now have online options that eliminate the paperwork.
Additional regulations and reporting are required from federal, state and local governments.
Owners' income may be subject to double taxation.
Variations of Corporations
S Corporations — An S Corporation is only a tax election. It enables the shareholders to treat the earnings and profits as distributions and have them pass through directly to the owners personal income taxes, however the owners' pay must be comparable to what any employee would be paid to do a similar job at another company. The IRS can reclassify the business and the shareholders will be liable for all payroll taxes if all requirements are not met.
Limited Liability Company (LLC) — An LLC was designed to provide many of the benefits of both partnerships and corporations. There is limited liability to the owners like a corporation, but the flow of profit works like a partnership. The income of the business is reported on the shareholders personal income taxes as income.
December 1, 2016 /0 Comments/by Joshua Azran
https://www.azranfinancial.com/wp-content/uploads/2015/02/people_town.jpg 997 1500 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2016-12-01 16:22:272019-10-01 12:14:06Accounting Consequences of Legal Business Organization
2016 Post-Election Tax Update
C-Corporation, Corporate Income Tax, Entrepreneur, Estate Tax, Federal Tax Law Updates, Individual Income Tax, Partnership Income Tax, Personal, S-Corporation, Tax Planning
Any change in Presidential Administration brings the possibility, indeed the likelihood, of tax law changes and the election of Donald Trump as the 45th President of the United States is no exception. During the campaign, President-elect Trump outlined a number of tax proposals for individuals and businesses. This letter highlights some of the President-elect's tax proposals. Keep in mind that a candidate's proposals can, and often do, change over the course of a campaign and also after taking office. This letter is based on general tax proposals made by the President-elect during the campaign and is intended to give a broad-brush snapshot of those proposals.
At the same time, the end of the year may bring some tax law changes before President Obama leaves office. This letter also highlights some of those possible changes with an eye on how late tax legislation could impact your year-end tax planning.
Campaign proposals
During the campaign, President-elect Trump called for reducing the number of individual income tax rates, lowering the individual income tax rates for most taxpayers, lowering the corporate tax rate, creating new tax incentives, and repealing the Affordable Care Act (ACA) (including presumably the ACA's tax-related provisions). The President-elect, in his campaign materials, highlighted several goals of tax reform:
Tax relief for middle class Americans
Simplify the Tax Code
Grow the American economy
Do not add to the debt or deficit
President-elect Trump also identified during the campaign a number of tax-related proposals that he intends to pursue during his first 100 days in office:
The Middle Class Tax Relief and Simplification Act: According to Trump, the legislation would provide middle class families with two children a 35 percent tax cut and lower the "business tax rate" from 35 percent to 15 percent.
Affordable Childcare and Eldercare Act: A proposal described by Trump during the campaign that would allow individuals to deduct childcare and elder care from their taxes, incentivize employers to provide on-site childcare and create tax-free savings accounts for children and elderly dependents.
Repeal and Replace Obamacare Act: A proposal made by Trump during the campaign to fully repeal the ACA.
American Energy & Infrastructure Act: A proposal described by Trump during the campaign that "leverages public-private partnerships, and private investments through tax incentives, to spur $1 trillion in infrastructure investment over 10 years."
Individual income taxes
The last change to the individual income tax rates was in the American Taxpayer Relief Act of 2012 (ATRA), which raised the top individual income tax rate. Under ATRA, the current individual income tax rates are 10, 15, 25, 28, 33, 35, and 39.6 percent. During the campaign, President-elect Trump proposed a new rate structure of 12, 25 and 33 percent:
Current rates of 10% and 15% = 12% under new rate structure.
Current rates of 33%, 35% and 39.6% = 33% under new rate structure.
This rate structure mirrors one proposed by House Republicans earlier this year. During the campaign, President-elect Trump did not detail the precise income levels within which each bracket percentage would fall, instead generally estimating for joint returns a 12% rate on income up to $75,000; a 25% rate for income between $75,000 and $225,000; and 33% on income more than $225,000 (brackets for single filers will be half those dollar amounts) and "low-income Americans" would have a 0% rate. As further details emerge, our office will keep you posted.
Closely-related to the individual income tax rates are the capital gains and dividend tax rates. The current capital gains rate structure, imposed based upon income tax brackets, would presumably be re-aligned to fit within President-elect Trump's proposed percent income tax bracket levels.
AMT and more
President-elect Trump proposed during the campaign to repeal the alternative minimum tax (AMT). The last time that Congress visited the AMT lawmakers voted to retain the tax but to provide for inflation-adjusted exemption amounts
During the campaign, Trump proposed to repeal the federal estate and gift tax. The unified federal estate and gift tax currently starts for estates valued at $5.49 million for 2017 (essentially double at $10.98 million for married individuals), Trump, however, also proposed a "carryover basis" rule for inherited stock and other assets from estates of more than $10 million. This additional proposal has already been criticized by some Republican members of Congress, while some Democrats have raised repeal of the federal estate tax as a non-starter.
Other proposals made by President-elect Trump during the campaign would limit itemized deductions, eliminate the head-of-household filing status and eliminate all personal exemptions. President-elect Trump also has called for increasing the standard deduction. Under Trump's plan, the standard deduction would increase to $15,000 for single individuals and to $30,000 for married couples filing jointly. In contrast, the 2017 standard deduction amounts under current law are $6,350 and $12,700, respectively, as adjusted for inflation
Possible new family-oriented tax breaks were discussed by President-elect Trump during the campaign. These include the creation of dependent care savings accounts, changes to earned income tax credit and enhanced deductions for child care and eldercare.
The Affordable care Act (ACA) created a number of new taxes that impact individuals and businesses. These taxes range from an excise tax on medical devices to taxes on high-dollar health insurance plans. The ACA also created the net investment income (NII) tax and the Additional Medicare Tax, both of which generally impact higher income taxpayers. The ACA also made significant changes to the medical expense deduction and other rules that affect individuals. For individuals and employers, the ACA created new mandates to carry or offer insurance, or otherwise pay a penalty.
President-elect Trump made repeal of the ACA one of the centerpieces of his campaign. During the campaign, the President-elect said he would call a special session of Congress to repeal the ACA. At this time, how repeal may move through Congress remains to be seen. Lawmakers could vote to repeal the entire ACA or just parts. Our office will keep you posted of developments as they unfold.
Business tax proposals
On the business front, President-elect Trump highlighted small businesses, the corporate tax rate, and some international proposals during his campaign. Along with simplification, and the reduction, of taxes for small business.
Particularly for small businesses, Trump has proposed a doubling of the Code Sec. 179 small business expensing election to $1 million. Trump has also proposed the immediate deduction of all new investments in a business, which has also been endorsed by Congressional tax reform/simplification advocates.
The current corporate tax rate is 35 percent. President-elect Trump called during the campaign for a reduction in the corporate tax rate to 15 percent. He also proposed sharing that rate with owners of "pass through" entities (sole proprietorships, partnerships and S corporations), but only for profits that are put back into the business.
Based on campaign materials, a one-time reduced rate would also be available to encourage companies to repatriate earnings of foreign subsidiaries that are held offshore. Many more details about these corporate and international tax proposals are expected.
Year-end 2016
More immediately, the calendar is quickly turning to 2017. Congress will meet for a "lame duck" session and is expected to take up tax legislation. Exactly what tax legislation Congress will consider before year-end remains to be seen. Every lawmaker has his or her "key" legislation to advance before the year-end. They include:
Legislation to renew some expiring tax extenders, especially energy extenders.
Legislation to fund the federal government, including the IRS, through the end of the 2017 fiscal year.
Legislation to enhance retirement savings for individuals.
Legislation to help citrus farmers, small businesses and more.
Some of these bills, if passed and signed into law, could impact year-end tax planning. The expiring extenders include the popular higher tuition and fees deduction along with some targeted business incentives. If these extenders are renewed, or made permanent, our office can assist you in maximizing their potential value in year-end tax planning.
Another facet of year-end tax planning is looking ahead. President-elect Trump has proposed some significant changes to the Tax Code for individuals and businesses. If these proposals become law, especially any reduction in income tax rates, and are made retroactive to January 1, 2017, your tax planning definitely needs to be reviewed. Our office will work with you to maximize any potential tax savings.
Working with Congress
When the 115th Congress convenes in January 2017, it will find the GOP in control of both the House and Senate, therefore allowing Trump to move forward on his proposals more easily. It remains to be seen, however, what compromises will be necessary between Congress and the Trump Administration to find common ground. In particular, too, compromise will likely be needed to bring onboard both GOP fiscal conservatives who will want revenue offsets to pay for tax reduction, and Senate Democrats who have the filibuster rule to prevent passage of tax bills with fewer than 60 votes. Beyond considering tax proposals one tax bill at a time, it remains to be seen whether proposals can be packaged within a broader mandate for "tax reform" and "tax simplification."
The information generally available now about President-elect Trump's tax proposals is based largely on statements by him during the campaign and campaign materials. President-elect Trump will take office January 20, 2017. Between now and then, more details about his tax proposals may be available.
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2016-11-16 11:28:032019-10-01 12:14:062016 Post-Election Tax Update
2013 Third Quarter Federal Tax Developments
C-Corporation, Corporate Income Tax, Entrepreneur, Federal Tax Law Updates, Individual Income Tax, Partnership Income Tax, S-Corporation, Tax Planning
IRS shutdown
On October 1, IRS offices across the country emptied as most of the agency's employees were furloughed following a lapse in appropriations. Nearly 90 percent of the IRS's 90,000 employees were furloughed on October 1 after Congress failed to pass legislation to keep the IRS and other federal agencies operating after the end of the government's fiscal year (FY) 2013. The IRS explained that some functions would continue during the government shutdown, including the processing of tax payments, criminal investigations and some litigation. The IRS reminded taxpayers that the underlying tax law remains in effect, as do their tax obligations during the shutdown.
Employer mandate
In July, the White House announced a one-year delay in the employer shared responsibility payment and employer/insurer reporting under the Patient Protection and Affordable Care Act (Affordable Care Act). The Affordable Care Act generally requires applicable large employers to pay an assessable payment if, among other circumstances, the employer fails to offer full-time employers and their dependents the opportunity to enroll in minimum essential coverage. The Affordable Care Act also requires large employers and many insurers to file annual returns reporting minimum essential coverage. After the White House's announcement, the IRS issued transition relief and proposed regulations. The IRS reported that it is exploring simplification of employer/insurer reporting.
Individual mandate
The IRS issued final regulations on the Affordable Care Act's individual shared responsibility requirements in August. The individual mandate generally requires individuals to carry minimum essential health coverage after 2013 unless they qualify for an exemption. An individual who does not carry minimum essential coverage and does not qualify for an exception must pay a penalty.
Repair regulations
In September, the IRS issued long-awaited final regulations on the treatment of costs to acquire, produce or improve tangible property. The final regulations impact any industry that uses tangible property, real or personal, the IRS explained. In the final regulations, the IRS added many taxpayer-friendly provisions, including a revised de minimis safe harbor, a routine maintenance safe harbor for buildings and new safe harbors for small taxpayers. Taxpayers will apply the final regulations to determine whether they can deduct costs as repairs or if they must capitalize the costs and recover them over a period of years.
Same-sex marriage/domestic partners
Following the U.S. Supreme Court's decision to strike down Section 3 of the Defense of Marriage Act (DOMA) ( E.S. Windsor, June 28, 2013), the IRS issued guidance for taxpayers and tax professionals in August. The IRS announced a general rule recognizing same-sex marriage nationwide. Same-sex married couples are treated as married for all federal tax purposes, including income and estate taxes, the IRS explained.
However, the IRS's treatment of married same-sex couples does not extend to domestic partners. The IRS explained that domestic partners are not considered married for federal tax purposes because they are not married under state law.
Net investment income tax
The Affordable Care Act imposes a 3.8 percent surtax on qualified net investment income under new Code Sec. 1411, generally effective for tax years beginning after December 31, 2012. In August, the IRS released a draft version of Form 8960, Net Investment Income Tax. The IRS is expected to finalize Form 8960 before the start of the 2014 filing season. The IRS is also expected to issue final regulations about the net investment income surtax before year-end to clarify many questions about the scope of the surtax.
The leaders of the House and Senate tax writing committee launched a nationwide tax reform tour during the summer of 2013. Rep. Dave Camp, R-Mich. and Sen. Max Baucus, D-Mont., visited several cities to promote comprehensive tax reform. At the same time, President Obama proposed to eliminate some business tax preferences in exchange for a reduction in the corporate tax rate. President Obama also proposed to tax carried interest as ordinary income.
Tax extenders
After 2013, many popular but temporary tax incentives (known as extenders) are scheduled to expire. They include the state and local sales tax deduction, the teacher's classroom expense deduction, the research tax credit, transit benefits parity, and many more. Some lawmakers in Congress have proposed to include the extenders in year-end comprehensive tax reform legislation, but leaders in the House and Senate have been cool to this idea. More likely, these incentives will be extended for one or two years in a year-end stand-alone bill or linked to other legislation. Our office will keep you posted of developments on the fate of these valuable tax incentives.
S corps
In August, the IRS announced exclusive simplified methods for taxpayers to request late S corporation elections. The IRS consolidated and expanded earlier guidance for taxpayers requesting late S corporation elections, late Electing Small Business Trust elections, late Qualified Subchapter S Trust Elections, Qualified Subchapter S Subsidiary elections, and certain late corporate classification elections.
Small employer health insurance tax credit
Qualified small employers may be eligible for the Code Sec. 45R tax credit that is designed to help offset the cost of providing health insurance to their employees. In August, the IRS issued proposed reliance regulations on the credit. In tax years beginning after 2013, a qualified small employer must participate in the Small Business Health Options Program (SHOP) to take advantage of the credit. In September, the White House announced a delay in the start of SHOP.
The IRS announced in September that the simplified per diem rates that taxpayers can use to reimburse employees for expenses incurred during travel after September 30, 2013. The high-cost area per diem increases from $242 to $251 and the low-cost area increases from $163 to $170. In 2012, the IRS did not increase the per diem rates, reflecting a directive from the White House to federal agencies to curb rising travel costs.
The IRS updated its equitable innocent spouse relief procedures in September. The IRS explained that the updated procedures are intended to give greater deference to the presence of abuse in a relationship. Some of the factors that the IRS uses to weigh a request for equitable innocent spouse relief were also made more taxpayer-friendly.
Worker classification
The Tax Court held in August that it lacks jurisdiction to review an IRS determination of worker status. The case arose from a request for the IRS to determine a worker's status. The Tax Court found there was no audit or examination as the IRS was simply responding to the taxpayer's request.
Collection due process cases
Taxpayers subject to IRS levy are generally entitled to a pre-levy hearing (a collection due process (CDP) hearing or an equivalent hearing). The Treasury Inspector General for Tax Administration (TIGTA) reported in September that it had discovered some concerns about the handling of CDP cases by the IRS. TIGTA discovered delays in the initial processing of requests for CDP hearings.
LILO/SILO transactions
In a case of first impression, the Tax Court applied the substance-over-form doctrine and found that an insurance company's lease-in, lease-out (LILO) and sale-in, sale-out (SILO) transactions were not leases ( John Hancock Life Insurance Co. (USA), 141 TC No. 1). The Tax Court held that the taxpayer could not deduct depreciation, rental expenses, interest expenses, and transactional costs connected with the transactions.
Code Sec. 199 provides a deduction for qualified domestic production activities. In August, the IRS determined that a taxpayer could claim the Code Sec. 199 deduction for in-store photo production activities. However, the taxpayer could not claim the deduction where it only transferred a customer's photos onto DVDs because those activities were a service and not the manufacturing of a product.
IRS administration
President Obama has proposed John Koskinen to serve as the next Commissioner of Internal Revenue. If confirmed by the Senate, Koskinen would replace IRS Principal Deputy Commissioner Daniel Werfel. Koskinen previously served in leadership roles with the Federal Home Loan Mortgage Corporation (Fannie Mae).
If you have any questions about these or other federal tax developments that may impact you or your business, please contact our office.
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2013-10-22 00:06:252019-10-01 12:14:062013 Third Quarter Federal Tax Developments
Notice of Health Insurance Exchanges
C-Corporation, Corporate Income Tax, Entrepreneur, Federal Tax Law Updates, S-Corporation
As you may know, the health care law – the Patient Protection and Affordable Care Act (PPACA) – requires most individuals (including children and other dependents) to carry health insurance, beginning January 1, 2014. The law also requires the establishment of a health insurance exchange in all states by October 1, 2013. The goal is that exchanges, working with private insurers, will act as a marketplace and provide "one-stop shopping" for individuals and families who may need health insurance or who seek less expensive coverage. A companion program – the Small Business Health Options Program or SHOP Exchange – will assist small businesses that want to offer insurance to their employees.
PPACA amended the Fair Labor Standards Act (FLSA) to require that employers provide each employee with notice about the exchanges. The notice requirement applies to employers that employ one or more employees who are engaged in, or produce goods for, interstate commerce. An employer must have at least $500,000 in business annually. The notice requirement also applies to hospitals, schools, and government agencies.
Employers must provide notice to their existing employees by October 1, 2013, and must provide notice to new employees hired on or after October 1, 2013. Each employee must receive notice, regardless of the employee's health plan enrollment status and part- or full-time employment status. Notice may be provided in writing or electronically under the Department of Labor's electronic disclosure rules.
The notice must inform the employee:
Of the existence of the exchange, the services provided by the exchange, and contact information for the exchange.
That he or she may be eligible for a premium tax credit under the Internal Revenue Code if (a) the employer pays less than 60 percent of the cost of health insurance offered by the employee; and (b) the employee purchases health insurance through the exchange.
That an employee who purchases health insurance through an exchange may lose the employer's (tax-free) contribution to the cost of health insurance offered by the employer.
To satisfy this notice requirement, the Department of Labor has provided model notices on its website, at http://www.dol.gov/ebsa/healthreform/. The website provides one model for employers who offer a health plan to some or all of their employees, and another model for employers who do not offer a health plan. Employers may modify the notice, as long as it meets the content requirements described above.
If you have questions about this requirement or want help to comply with the requirement, please contact our office.
September 12, 2013 /0 Comments/by Joshua Azran
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2013-09-12 15:06:382019-10-01 12:14:06Notice of Health Insurance Exchanges
Post Tax Season Update & 2013 First Quarter Federal Tax Developments
April 15 has come and gone but it's not time to stop thinking about taxes and strategic tax planning opportunities. Since the start of 2013, there have been many new federal tax developments, which will impact tax planning for this year and beyond. As 2013 unfolds, many changes made to the Tax Code by the American Taxpayer Relief Act of 2012 (ATRA) take effect. Additionally, there are new taxes to take into account because of the health care reform package, along with enhancements to many tax credits and deductions. Now is a good time to revisit these developments and explore how they will affect your strategic tax plans. Planning today can help maximize your tax savings going forward. As always, please give our office a call or email if you have any questions.
Tax planning and ATRA
Returns just filed (or that will be filed under extension by October 15, 2013) reflect the tax laws as they existed in 2012 (with some expired provisions renewed retroactively for 2012 by ATRA). Looking ahead, your 2013 return to be filed in 2014 will reflect the many changes to the Tax Code made by ATRA. Because the new law was passed at the beginning of the year, it was overshadowed by the filing season. However, its provisions impact every taxpayer and it's vital to take time to gauge how they will affect you. The list of changes made by ATRA is long: many generous tax incentives, such as the $1,000 child tax credit, enhanced adoption credit, and enhanced earned income credit, are made permanent. ATRA also permanently "patches" the alternative minimum tax (AMT), which definitely will impact planning for taxpayers liable for the AMT. The new law also extends permanently the Bush-era tax rate cuts for individuals except taxpayers with taxable income above $400,000 ($450,000 for married couples filing a joint return). Income above these levels is taxed at 39.6 percent effective January 1, 2013. ATRA also increased the tax rates on qualified capital gains and dividends for higher income taxpayers. All these changes and more are set in motion by ATRA.January 10, 2013.
New proposals to consider
Looking ahead, some new proposals could impact tax planning in 2013 and beyond. President Obama has proposed to reduce the value to 28 percent of certain deductions and exclusions that would otherwise reduce taxable income in the 33, 35 or 39.6 percent tax brackets. The President also re-proposed the so-called Buffett Rule, now referred to as the "Fair Share Tax" for taxpayers with incomes above $1 million (with full phase-in above $2 million). Moreover, the President has proposed to limit contributions and accruals on tax-favored retirement benefits, including IRAs, qualified plans, tax-sheltered annuities, and deferred compensation plans. The limit generally would apply when a taxpayer accumulates total retirement amounts that exceed the amount necessary to provide the maximum annuity permitted for a defined benefit plan. The President's proposals are expected to be debated in Congress as lawmakers and the White House try to reach an agreement on tax reform and deficit deduction. President Obama has said he wants an agreement before August, which could significantly change your tax planning for 2013 and beyond. Our office will keep you posted of developments.
NII surtax takes effect
The 3.8 percent Medicare surtax on net investment income (NII) became effective January 1, 2013. The NII surtax on individuals equals 3.8 percent of the lesser of: Net investment income for the tax year, or the excess, if any of the individual's modified adjusted gross income (MAGI) for the tax year, over the threshold amount. The threshold amount in turn is equal to $250,000 in the case of a taxpayer making a joint return or a surviving spouse, $125,000 in the case of a married taxpayer filing a separate return, and $200,000 in any other case.
The IRS issued proposed regulations in 2012 intending them to be "reliance regulations." Nonetheless, taxpayers continue to be confused over certain sections. Although final regulations are promised "within 2013" so they would be available for the 2013 tax year and 2014 filing season, current misinterpretation of the proposed regulations can impact on tax strategies now being put into motion in 2013. Any misinterpretation can also bear on 2013 estimated tax that may be due to cover any 3.8 percent NII surtax liability. Our office will keep you posted of developments.
Vehicle depreciation limits increase for 2013
Tax planning for 2013 is helped by the IRS's release of inflation-adjusted limitations on depreciation deductions for business-use of passenger automobiles, light trucks, and vans first placed in service during calendar year 2013. Some of the depreciation limits are identical to the limits for 2012; other ceilings have increased by $100. The 2013 dollar limits reflect the inflation adjustments both with the extension of bonus depreciation by ATRA and without. If bonus depreciation is allowed to lapse after 2013, as President Obama has proposed, the dollar limits for 2014 would be lower but would still be adjusted for inflation. The maximum depreciation limits under Code Sec. 280F for passenger automobiles first placed in service during the 2013 calendar year are: $11,160 for the first tax year ($3,160 if bonus depreciation does not apply); $5,100 for the second tax year; $3,050 for the third tax year; and $1,875 for each succeeding tax year. The maximum depreciation limits under Code Sec. 280F for trucks and vans first placed in service during the 2013 calendar year are slightly higher. Keep in mind that SUVs and pickup trucks with a gross vehicle weight rating (GVWR) in excess of 6,000 pounds continue to be exempt from the luxury vehicle depreciation caps based on a loophole in the operative definition.
IRS audits of business property write-offs on "stand-down"
The IRS announced in March that it had updated its 2012 directive that generally instructs employees to discontinue audits of costs to maintain, replace or improve tangible property. The updated directive tells employees not to begin examining those issues for tax years beginning on or after January 1, 2012 and before January 1, 2014. The directive retains the "stand-down" of audit activity in this area beginning in 2012. The IRS also advised that it intends to make changes to temporary regulations regarding certain de minimis rules, routine maintenance and more.
Prepare for employer and individual mandates under PPACA
The IRS issued long-awaited proposed reliance regulations on the employer mandate under the Patient Protection and Affordable Care Act (PPACA). An applicable large employer is an employer that employed an average of at least 50 full-time employees during the preceding calendar year, including full-time equivalent (FTE) employees. The statute defines a full-time employee as an employee who on average was employed for at least 30 hours of service per week.
The PPACA also generally requires individuals, unless exempt, to carry minimum essential health insurance coverage after 2013 or make a shared responsibility payment. The IRS has issued proposed regulations on the individual mandate. The proposed regulations, the IRS explained, are intended to mitigate the affordability test for related individuals.
IRS ramps up oversight of foreign accounts
The Foreign Account Tax Compliance Act (FATCA) gives the agency new tools to discover tax evasion. In January, Treasury and the IRS issued final regulations under FATCA that describe the requirements for foreign financial institutions (FFIs), nonfinancial foreign entities (NFFEs), and other taxpayers to comply with FATCA's reporting and withholding regimes on U.S. and foreign account holders. The 544-page regulation package seeks to harmonize the United States' regulatory requirements with the use of intergovernmental agreements (IGAs) to implement FATCA.
Simplified safe harbor for claiming home office deduction
The home office deduction is one of the most complex in the Tax Code. In response, the IRS announced a simplified safe harbor method for claiming the home office deduction for tax years beginning on or after January 1, 2013. Under the safe harbor, taxpayers determine the amount of deductible expenses for qualified business use of the home for the tax year by multiplying the allowable square footage by the prescribed rate. The allowable square footage cannot exceed 300 square feet and the prescribed rate is $5.00, which provides a maximum deduction under the safe harbor of $1,500. The IRS indicated it may revisit the prescribed rate amount in the future.
To conclude "Since the start of 2013, there have been many new federal tax developments, which will impact tax planning for this year and beyond."
If you have any questions about these or any other federal tax developments and their impact on tax planning, please contact our office at (310) 691-5040 or (818) 691-1234 or via e-mail at [email protected]
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2013-04-25 09:39:432019-10-01 12:14:06Post Tax Season Update & 2013 First Quarter Federal Tax Developments
Updated FAQ on Small Business Health Care Credit
C-Corporation, Corporate Income Tax, Entrepreneur, Federal Tax Law Updates, S-Corporation, Startup, Tax Planning
If you are a small employer with fewer than 25 full-time equivalent employees, pay an average wage of less than $50,000 a year, and pay at least half of your employee health insurance premiums then you may be eligible for the Small Business Health Care Tax Credit.
For tax years 2010 through 2013, the maximum credit is 35 percent for small business employers and 25 percent for small tax-exempt employers such as charities. An enhanced version of the credit will be effective beginning Jan. 1, 2014. The IRS is expected to issue additional information about the enhanced version as it becomes available. In general, on Jan. 1, 2014, the rate will increase to 50 percent and 35 percent, respectively.
Here's what this means for you. If you pay $50,000 a year toward workers' health care premiums – and if you qualify for a 15 percent credit, you save $7,500. If, in 2014, you qualify for a slightly larger credit, say 20 percent, your savings go from $7,500 a year to $12,000 a year.
Even if you are a small business employer who does not owe tax for the year, you can carry the credit back or forward to other tax years. Also, since the amount of the health insurance premium payments are more than the total credit, eligible small businesses can still claim a business expense deduction for the premiums in excess of the credit. That's both a credit and a deduction for employee premium payments.
There is good news for small tax-exempt employers too. The credit is refundable, so even if you have no taxable income, you may be eligible to receive the credit as a refund so long as it does not exceed your income tax withholding and Medicare tax liability.
This credit was provided by the Patient Protection and Affordable Care (PPAC) Act as part of a design to reform the United States health care system and encourage employer's shared responsibility. If you have any questions regarding this credit or any other provision of PPAC Act, please call our office at (310) 691-5040 or (818) 691-1234 or e-mail us at [email protected]
March 19, 2013 /0 Comments/by Joshua Azran
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2013-03-19 11:39:362019-10-01 12:14:06Updated FAQ on Small Business Health Care Credit
Overview of the 2012 American Taxpayer Relief Act / Fiscal Cliff Legislation
C-Corporation, Corporate Income Tax, Entrepreneur, Estate Tax, Federal Tax Law Updates, Gift Tax, Individual Income Tax, International Tax, Partnership Income Tax, S-Corporation, Startup, State Tax, Tax Planning
After weeks, indeed months of proposals and counter-proposals, seemingly endless negotiations and down-to-the-wire drama, Congress has passed legislation to avert the tax side of the so-called "fiscal cliff." The American Taxpayer Relief Act permanently extends the Bush-era tax cuts for lower and moderate income taxpayers, permanently "patches" the alternative minimum tax (AMT), provides for a permanent 40 percent federal estate tax rate, renews many individual, business and energy tax extenders, and more. In one immediately noticeable effect, the American Taxpayer Relief Act does not extend the 2012 employee-side payroll tax holiday.
The American Taxpayer Relief Act is intended to bring some certainty to the Tax Code. At the same time, it sets stage for comprehensive tax reform, possibly in 2013. Moreover, it creates important planning opportunities for taxpayers, which we can discuss in detail.
Unlike the two-year extension of the Bush-era tax cuts enacted in 2010, the debate in 2012 took place in a very different political and economic climate. If Congress did nothing, tax rates were scheduled to increase for all taxpayers at all income levels after 2012. President Obama made it clear that he would veto any bill that extended the Bush-era tax cuts for higher income individuals. The President's veto threat gained weight after his re-election. Both the White House and the GOP realized that going over the fiscal cliff would jeopardize the economic recovery, and the American Taxpayer Relief Act is, for the moment, their best compromise.
Tax rates. The American Taxpayer Relief Act extends permanently the Bush-era income tax rates for all taxpayers except for taxpayers with taxable income above certain thresholds:
$400,000 for single individuals, $450,000 for married couples filing joint returns, and $425,000 for heads of households. For 2013 and beyond, the federal income tax rates are 10, 15, 25, 28, 33, 35, and 39.6 percent. In comparison, the top rate before 2013 was 35 percent. The IRS is expected to issue revised income tax withholding tables to reflect the 2013 rates as quickly as possible and provide guidance to employers and self-employed individuals.
Additionally, the new law revives the Pease limitation on itemized deductions and personal exemption phaseout (PEP) after 2012 for higher income individuals but at revised thresholds. The new thresholds for being subject to both the Pease limitation and PEP after 2012 are $300,000 for married couples and surviving spouses, $275,000 for heads of households, $250,000 for unmarried taxpayers; and $150,000 for married couples filing separate returns.
Capital gains. The taxpayer-friendly Bush-era capital gains and dividend tax rates are modified by the American Taxpayer Relief Act. Generally, the new law increases the top rate for qualified capital gains and dividends to 20 percent (the Bush-era top rate was 15 percent). The 20 percent rate will apply to the extent that a taxpayer's income exceeds the $400,000/$425,000/$450,000 thresholds discussed above. The 15 percent Bush-era tax rate will continue to apply to all other taxpayers (in some cases zero percent for qualified taxpayers within the 15-percent-or-lower income tax bracket).
Payroll tax cut. The employee-side payroll tax holiday is not extended. Before 2013, the employee-share of OASDI taxes was reduced by two percentage points from 6.2 percent to 4.2 percent up the Social Security wage base (with a similar tax break for self-employed individuals). For 2013, two percent reduction is no longer available and the employee-share of OASDI taxes reverts to 6.2 percent. The employer-share of OASDI taxes remains at 6.2 percent. In 2012, the payroll tax holiday could save a taxpayer up to $2,202 (taxpayers earning at or above the Social Security wage base for 2012). As a result of the expiration of the payroll tax holiday, everyone who receives a paycheck or self-employment income will see an increase in taxes in 2013.
AMT. In recent years, Congress routinely "patched" the AMT to prevent its encroachment on middle income taxpayers. The American Taxpayer Relief Act patches permanently the AMT by giving taxpayers higher exemption amounts and other targeted relief. This relief is available beginning in 2012 and going forward. The permanent patch is expected to provide some certainty to planning for the AMT. No single factor automatically triggers AMT liability but some common factors are itemized deductions for state and local income taxes; itemized deductions for miscellaneous expenditures, itemized deductions on home equity loan interest (not including interest on a loan to build, buy or improve a residence); and changes in income from installment sales. Our office can help you gauge if you may be liable for the AMT in 2013 or future years.
Child tax credit and related incentives. The popular $1,000 child tax credit was scheduled to revert to $500 per qualifying child after 2012. Additional enhancements to the child tax credit also were scheduled to expire after 2012. The American Taxpayer Relief Act makes permanent the $1,000 child tax credit. Most of the Bush-era enhancements are also made permanent or extended. Along with the child tax credit, the new law makes permanent the enhanced adoption credit/and income exclusion; the enhanced child and dependent care credit and the Bush-era credit for employer-provided child care facilities and services.
Education incentives. A number of popular education tax incentives are extended or made permanent by the American Taxpayer Relief Act. The American Opportunity Tax Credit (an enhanced version of the Hope education credit) is extended through 2017. Enhancements to Coverdell education savings accounts, such as the $2,000 maximum contribution, are made permanent. The student loan interest deduction is made more attractive by the permanent suspension of its 60-month rules (which had been scheduled to return after 2012). The new law also extends permanently the exclusion from income and employment taxes of employer-provided education assistance up to $5,250 and the exclusion from income for certain military scholarship programs. Additionally, the above-the-line higher education tuition deduction is extended through 2013 as is the teachers' classroom expense deduction.
Charitable giving. Congress has long used the tax laws to encourage charitable giving. The American Taxpayer Relief Act extends a popular charitable giving incentive through 2013: tax-free IRA distributions to charity by individuals age 70 ½ and older up to maximum of $100,000 for qualified taxpayer per year. A special transition rule allows individuals to recharacterize distributions made in January 2013 as made on December 31, 2012. The new law also extends for businesses the enhanced deduction for charitable contributions of food inventory.
Federal estate tax. Few issues have complicated family wealth planning in recent years as has the federal estate tax. Recent laws have changed the maximum estate tax rate multiple times. Most recently, the 2010 Taxpayer Relief Act set the maximum estate tax rate at 35 percent with an inflation-adjusted exclusion of $5 million for estates of decedents dying before 2013. Effective January 1, 2013, the maximum federal estate tax will rise to 40 percent, but will continue to apply an inflation-adjusted exclusion of $5 million. The new law also makes permanent portability between spouses and some Bush-era technical enhancements to the estate tax.
The business tax incentives in the new law, while not receiving as much press as the individual tax provisions, are valuable. Two very popular incentives, bonus depreciation and small business expensing, are extended as are many business tax "extenders."
Bonus depreciation/small business expensing. The new law renews 50 percent bonus depreciation through 2013 (2014 in the case of certain longer period production property and transportation property). Code Sec. 179 small business expensing is also extended through 2013 with a generous $500,000 expensing allowance and a $2 million investment limit. Without the new law, the expensing allowance was scheduled to plummet to $25,000 with a $200,000 investment limit.
Small business stock. To encourage investment in small businesses, the tax laws in recent years have allowed noncorporate taxpayers to exclude a percentage of the gain realized from the sale or exchange of small business stock held for more than five years. The American Taxpayer Relief Act extends the 100 percent exclusion from the sale or exchange of small business stock through 2013.
Tax extenders. A host of business tax incentives are extended through 2013. These include:
Research tax credit or R&D credit
Work Opportunity Tax Credit (WOTC)
New Markets Tax Credit
Employer wage credit for military reservists
Tax incentives for empowerment zones
Indian employment credit
Railroad track maintenance credit
Subpart F exceptions for active financing income
Look through rules for related controlled foreign corporation payments
For individuals and businesses, the new law extends some energy tax incentives. The Code Sec. 25C, which rewards homeowners who make energy efficient improvements, with a tax credit is extended through 2013. Businesses benefit from the extension of the Code Sec. 45 production tax credit for wind energy, credits for biofuels, credits for energy-efficient appliances, and many more.
The negotiations and passage of the new law are likely a dress rehearsal for comprehensive tax reform during President Obama's second term. Both the President and the GOP have called for making the Tax Code more simple and fair for individuals and businesses. The many proposals for tax reform include consolidation of the current individual income tax brackets, repeal of the AMT, moving the U.S. from a worldwide to territorial system of taxation, and a reduction in the corporate tax rate. Congress and the Obama administration also must tackle sequestration, which the American Taxpayer Relief Act delayed for two months. All this and more is expected to keep federal tax policy in the news in 2013. Our office will keep you posted of developments.
If you have any questions about the American Taxpayer Relief Act, please contact Azran Financial at (310) 691-5040 or (818) 691-1234 or via e-mail at [email protected] We can schedule an appointment to discuss how the changes in the new law may be able to maximize your tax savings.
January 4, 2013 /0 Comments/by Joshua Azran
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2013-01-04 09:00:402019-10-01 12:14:07Overview of the 2012 American Taxpayer Relief Act / Fiscal Cliff Legislation
Planning Opportunities for New 3.8-Percent Medicare Tax Using S Corporations
C-Corporation, Corporate Income Tax, Entrepreneur, Federal Tax Law Updates, Individual Income Tax, Partnership Income Tax, S-Corporation, Startup, Tax Planning
The Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act implemented Code Sec. 1411, which imposes a new 3.8-percent Medicare tax on unearned income of higher-income individuals. The tax will take effect January 1, 2013, and applies to the net investment income of individuals, estates, and trusts that exceeds specified thresholds. Although the tax does not apply to corporations, it will apply to dividends and other passive income derived from corporations.
Because the tax on net investment income applies to individuals, it may apply to amounts received by individuals from passthrough entities, such as partnerships, limited liability companies, and S corporations. Under general principles, items of income that flow through a partnership, S corporation, or limited liability company (LLC) to partners, shareholders, or members retain their character. Thus, for example, interest income earned by a partnership is still characterized as interest when it passes through to a partner.
The tax, known as the Medicare contribution tax, equals 3.8 percent of the lesser of (1) an individual's net investment income or (2) the excess of the individual's modified adjusted gross income (AGI) over the threshold amount. The thresholds are $250,000 for married taxpayers filing a joint return; $125,000 for married taxpayers filing a separate return; and $200,000 for all other taxpayers.
Trusts and estates are subject to a much lower threshold. They should strive to distribute their income to their individual beneficiaries to minimize the tax.
The tax does not apply to non-resident aliens, charitable trusts, or corporations.
Net investment income includes gross income from interest, dividends, royalties, and rents, as well as net gain from the disposition of property, unless such income is derived from a passive activity. The tax also applies to other gross income from a trade or business that is a passive activity. Thus, the application of the tax depends on the character of the amounts and the treatment of amounts received from these entities.
The tax applies to passive income, which is income from a trade or business that is a passive activity under Code Sec. 469. An activity is passive if it involves the conduct of a trade or business in which the taxpayer does not materially participate. Very generally, material participation exists if the taxpayer is involved in the operations of the activity on a regular, continuous, and substantial basis. Accordingly, if the individual materially participates in the entity's business, the tax on net investment income does not apply to income from the entity. If the individual does not materially participate, the income is characterized as passive and may be subject to the tax under Code Sec. 1411(c)(2).
A sole proprietor by definition manages his or her business. Thus, the sole proprietor materially participates in his or her business and would not have to pay the 3.8-percent tax on income of the proprietorship.
Income from a partnership, S corporation, or LLC is often characterized as passive income if the individual does not materially participate in the business of the entity. In the past, passive income was seen as beneficial, because it could be used to offset passive losses. Thus, in the past, taxpayers have desired passive income and may even have planned for it. Now, because of the net investment income tax, certain taxpayers may prefer not to have income characterized as passive.
Employees generally are subject to Social Security (FICA or SECA) taxes on their wage income, amounting to 7.65 percent contributed by the employee and the employer. This also applies to wages paid to partners. Self-employed individuals pay a similar tax (15.3 percent, which includes both the employee's and the employer's shares) on their business income. This income is characterized as net earnings from self employment.
The current payroll tax holiday has reduced an employee's employment tax share to 5.65 percent (13.3 percent for self-employed). Absent further legislation, the rates will revert to their previous levels in 2013.
Net earnings from self-employment are specifically excluded from being characterized as net investment income (Code Sec. 1411(c)(6)). This eliminates the possibility of an individual being subject to Medicare taxes on both earnings and unearned income.
Partnership Income
Earnings or business income derived from a partnership, which flows through the entity to the general partners, is characterized as net earnings from self-employment. Therefore, it is subject to self-employment tax, and is not subject to the 3.8-percent tax on net investment income.
Income that flows through to the limited partners is not treated as net earnings from self-employment. It will be subject to the 3.8-percent net investment income tax, but not the Social Security tax.
If the same individual is both a general partner and a limited partner, the characterization of the income is not so clear and likely will be subject to greater examination by the IRS.
S Corporation Income
Unlike a partnership, an S corporation's income that passes through to its owners (its shareholders) is not per se characterized as net earnings from self-employment, because dividends on shares of stock issued by the S corporation are excluded from this characterization. Similarly, normal distributions actually made by an S corporation to its shareholders are not treated as net earnings from self-employment. However, this contrasts with distributions that are payments of wages to shareholder-employees, which are subject to Social Security taxes.
Thus, shareholder-employees can avoid Social Security taxes by withdrawing funds from the S corporation as a distribution, rather than as wages. However, if the employee takes no salary or an unreasonably low salary, the courts generally have supported the IRS in recharacterizing at least a portion of the distributions as wages subject to Social Security taxes.
Income that passes through to S corporation shareholders, as well as distributions, will be subject to the 3.8-percent Medicare tax unless the shareholder materially participates in the business (i.e., the S corporation's business is not a passive activity with respect to the shareholder). In the latter case, however, the income may successfully avoid both Social Security taxes and Medicare taxes. Furthermore, gain on the sale or redemption of the S corporation interest likewise should not be net investment income under this interpretation if the shareholder materially participates in the business.
Planning Strategies
With these consequences in mind, taxpayers may now be more inclined to establish an S corporation to run their business as long as they are materially involved in the operation of the business and pay reasonable salaries to shareholder-employees. This can be accomplished with a variety of structures.
The basic structure is to operate the business through an S corporation or through an LLC that elects to be taxed as an S corporation. The shareholder-owners must be materially involved in the business. Wages paid to shareholder-employees will be subject to Social Security taxes, but distributions, passthrough income, and net gains from the sale or redemption of the shareholder's interest in the S corporation will not be subject to the net investment income tax.
If a shareholder does not materially participate in the business operations, the net investment income tax will apply to income items paid or distributed to the shareholder (other than wages).
Variations of this basic structure can be used, and the tax consequences should be the same. S corporations can only have one class of stock. An LLC with one class of interests and no preferred income allocations or distributions may elect S corporation treatment for tax purposes and secure this same treatment. Another variation can be used if there are varying interests. An S corporation owned by the business's operators can become a member of an LLC with other investors who are not eligible to hold S corporation stock (e.g. foreign investors) becoming members of the LLC.
Another possible structure uses a corporation as the manager of an LLC. The corporate manager in this case would have the authority to bind the LLC. A member investing in the LLC as a limited partner would not be subject to self-employment taxes. If involved in the business, the limited partner would not be subject to the net investment income tax. It may not be so clear, however, how to treat an LLC member who is involved in the business for self-employment tax purposes. Finally, a limited partnership with an S corporation as the sole general partner could also obtain these benefits. Income would pass through and the limited partners would qualify for the limited partner exception to self-employment taxes.
The IRS has argued that LLCs should be treated as limited partnerships, but the courts generally have not accepted this analysis.
Under current law, it appears that investors may be able to use the S corporation structure to avoid most Social Security self-employment taxes and the net investment income tax. However, the IRS has yet to issue regulations on the 3.8-percent net investment income tax, and it remains to be seen whether potential IRS guidance on material participation in a business, or other interrelationships between the self-employment tax and net investment income tax provisions under the Code, will affect the use of these structures.
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2012-12-07 09:00:062019-10-01 12:14:07Planning Opportunities for New 3.8-Percent Medicare Tax Using S Corporations
California Income Tax Update
C-Corporation, Corporate Income Tax, Individual Income Tax, S-Corporation, State Tax
An estimated tax underpayment penalty will not be imposed against taxpayers who underpay their estimated California personal income taxes to the extent that the underpayment was created or increased as a result of the personal income tax rate increases just approved by the voters with the passage of Proposition 30. California law contains a safe-harbor provision for underpayments resulting from any provision of law that is chaptered during and operative for the taxable year of the underpayment. Taxpayers will not be required to make any catch-up payments.
Taxpayers should also be aware that the additional mental health tax imposed on taxpayers with taxable incomes above $1 million is not affected by Proposition 30, and taxpayers will still be liable for the additional 1% tax on taxable income above $1 million.
Finally, taxpayers should be aware that the tax imposed on nonresident individuals participating in composite returns filed by corporations and pass-through entities is imposed at the highest marginal tax rate, which is now 12.3% for the 2012—2018 tax years.
Sellers of California real property should note the impact of the increased tax rates on the alternative withholding rate, under which sellers may choose to compute the amount of withholding based on the reportable gain from the sale rather than on a percentage of the total sales price.
Individuals and non-California partnerships making the election must compute the withholding on the reportable gain using the highest marginal personal income tax rate, which has increased to 12.3%. Withholding on amounts paid by a partnership to its foreign partners, which is at the maximum personal income tax rate, is likewise affected.
https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png 0 0 Joshua Azran https://www.azranfinancial.com/wp-content/uploads/2018/04/AF-Logo-space-300x104.png Joshua Azran2012-11-27 12:00:522019-10-01 12:14:07California Income Tax Update


text:
Signup with Github
5 things I learned about open source developers
Chen Ravid is a free software enthusiast and serial entrepreneur. He is one of the founding members and chief product officer at xs:code, a monetization platform for open source projects.
I've spent the past 12 months working intensely with open source developers. In previous ventures I worked on, my teams and I used open-source libraries, but this was the first time I actually crossed the lines from just another faceless person git cloning some code, to actually meeting the people behind the repository. It's been (and still is) an enlightening journey.
Strictly speaking, I'm not a developer myself. I can write code, but trust me – you wouldn't want to read it, let alone run it. I feel more comfortable on the product side. As a product manager and entrepreneur, I worked with a lot of software developers over the years. During that time, I've developed a deep appreciation to the trade and its unique craftsmanship. But open source developers, mainly those who start their projects from scratch and the developers that help maintaining them over long periods of time, have always been a mystery to me. Kept being amazed by how those developers created intricate pieces of software, spending countless hours of their spare time, over months and years – solely out of their own volition.
I Can't think of anything remotely similar happening in other industries, and the past year really caught me off guard. I wasn't sure what types of people I'd find behind the projects, but let me tell you – it was worth it.
They're not JUST smart
Developers are smart. They have to be. Writing code is an incredibly complicated task. The sheer brain power required to perform even some of the most basic tasks that from a users' perspective seem obvious to non-programmers, would blow your mind if you're not accustomed to it. I always say that working with developers is both extremely rewarding and extremely tough, because you need to deal with the smartest 1% on the planet. As such, they are demanding, and sometimes just trying to keep up with a developer trying to explain some complex concept, would cause my head to spin.
But open source developers have something extra. A lot of software developers spend most of their time working on tasks that are handed down in hierarchy. In many cases the developer has little say about the why. Developers have a lot of leeway on how to perform a task, but rarely do they have the chance to partake in the why they are doing it.
Open source developers not only have the skills to code, but also have the foresight and systematic point of view to decide the what, the how – and most importantly, the why. It might seem trivial, but the why is the most important part of any software project. If the why is week, the entire project might be useless. Open source developers who start projects from scratch, usually have a highly developed sense of why that burns so hard, they just cannot sit back. They have to do it. They have to code. This sense of purpose, of knowing the why, combined with extreme technical prowess and curiosity – is a rare quality possessed by few.
They have more than passion
The burning sensation I just mentioned is something that a lot of us feel sometimes. We all have ideas we're sure are great, but only a handful are willing to actually grind and put in the time and effort to execute them. It takes an extreme amount of passion to keep an open source project going for years. Only those who have a true passion for solving a problem, can go through the long and tedious process of creating and maintaining a useful, stable, production-grade project.
This problem solving passion is what drives many of the open source developers I've spoken to. Both the developers who created the projects, and the developers who help maintain them. It usually starts with an issue they encountered in their day job, that made them wonder "why isn't there a solution to this problem?". There is a wide chasm that stretches between "there's a problem" to "I'll solve this problem so everyone else can use my solution", and only a select few cross it. When the problem they started with is solved, it's their passion that drives them to continue exploring, develop more features and push the envelope further. There's no boss. No JIRA tasks. No deadlines or clients waiting for builds. It's pure passion.
They keep going
I was born in Israel. Many call it the Start-up nation, since Israel has the highest ratio of startups per capita in the world outside of silicon valley. I think it has something to do with the entrepreneurial spirit Israelis are instilled with from birth. But along with success stories like Waze, Wix, Fiverr and Mobileye, there are a lot of 'want-epreneurs' around. It's probably not unique to Israel, but as a local I can tell you I've met quite a few. People who think they have a great idea and can 'talk the talk', but lack the persistence to 'walk the walk' and actually put in the work to make it happen. Making a great product takes time. A lot of time. An idea is not enough, you need persistence to push things through.
Open source developers and maintainers have the unique ability to persist working on a project for a long time. No project is perfect at version 0.0.0.1. It takes time, work and discipline to continue working on something and make it actually usable. When I sat with some developers, going over their earliest versions made them laugh. Persistence is what made them go from a few messy functions, to complex projects, used in thousands of commercial applications.
They are the unsung heroes of code
I was going through some early commits with a developer, trying to understand how his project went from about 100 lines of code, to a massive library of Vue components he's been developing for more than 3 years. Turns out many of the features and components he developed, came from requests some of his early users sent him. He told me that he was so happy others were using his code, he felt obligated to help them out and develop what they had asked for.
Try comparing this to any other profession. Other than volunteers doing charity work, I cannot think of one professional lending his hard earned expertise, and little spare time, to help others working on commercial projects that are none his concern. True, the developer I mentioned was helping fellow developers who were not directly making money off of his code – they were working for the companies who did, but have you seen any lawyers drafting contracts for free for other lawyers who are not sure what to write?
This pure selflessness and capacity to share their knowledge is something I am hoping humanity will find in other places, not just programming. If we could save the world with code, I'm pretty sure open source developers would be leading the way.
They are under-compensated
Open source developers are not in it for the money. Clearly, right now, there isn't any. They do what they do thanks to the reasons I wrote above. Lucky us! But having interviewed dozens of open source developers, I started seeing cracks in the wall. Overworked, under-appreciated and sometimes even overlooked, open source developers are slowly realizing the harsh reality of under-compensation for their efforts.
Open source became so common, we rarely stop to think about the people behind it. Working in commercial software companies, we use open source components for almost everything. They are truly everywhere. I've read that 90% of commercial software developed today has some reliance on open source components or systems. These components became so common, you don't even think twice before using them.
If you worked on any commercial software and used an open source component – have you ever thought about the countless hours and sleepless nights that person or team had to pull so you'll have this incredible piece of software that just saved you months of work? True, some of us contribute back, but only a handful actually develop code from scratch for others to use.
If we want open source to keep growing, we need to understand that the good people behind it are not compensated enough. Actually, they are not compensated at all. When a developer takes the time to handle bug fixes, work on new features, support new framework versions and more – without ANY form of compensation, it might not last. I've seen numerous open source projects get abandoned by their developers because they just didn't have the time or resources to continue working on them. Too many bug reports, too much work to continue developing more features, handling security issue, adapting to new technologies coming out. Open source developers never asked for money, but if they don't get the resources they need to keep developing – we all stand to lose.
Open source is an incredible thing. Sometimes it feels like electricity. We all use it, but rarely think about what would happen if it were gone. The people with the rare traits described above, along with a unique combination of conditions, made open source what it is today. Ubiquitous. Free. Plentiful.
It seems to me the software industry needs to take a long, hard look at open source usage, and start thinking about how we can make sure open source developers have an incentive to maintain their projects, and make sure the next generation of developers will create the next generation of open source projects – for all of us. If we don't make sure to provide developers with the best conditions to keep going, even the smartest, most passionate, persistent and selfless of them all, would just might stop. Or just make their repositories private.
© 2020 All rights Reserved, xscode international Ltd.
Github and Github.com are the trademarks of Github, Inc. xs:code international Ltd. is not associated with Github, Inc.
Youtube Twitter Reddit Gitter Facebook-f
We use cookies to ensure that we give you the best experience on our website. If you continue to browse the site, you agree to the use of cookies. For more information on our use of cookies you may see our Privacy Policy.OkPrivacy policy

redpajama_set_name: RedPajamaCommonCrawl


I am looking to start my career in freelancing. I graduated with an English degree and a 4.7 grade average. I also have worked as a tutor and proofreader for college students.
Hello,I am currently working for an online content writing platform. I am very punctual, creative and open to suggestions and revisions.


text:
Skoda reveals first design sketches of new SLAVIA sedan for India
Skoda has unveiled the all-new Slavia premium mid-size sedan in the Indian market. The brand has released the design sketches of the new Skoda Slavia, revealing the exterior details of the new car. The brand has also announced that Slavia will make its official debut before the end of November 2021. The Skoda Slavia is the brand's second vehicle under the India Project 2.0.
The mid-size sedan underpins the MQB-A0-IN platform that made its debut on the Skoda Kushaq SUV in India. The Skoda Slavia sedan is developed chiefly at the SKODA AUTO Volkswagen India Technology Centre in Pune. Furthermore, Skoda Slavia will be locally produced at the Volkswagen Group's production facility in Pune, and the vehicle is designed to meet India's new, stricter safety and emissions specifications.
Skoda Slavia – Exterior Design Highlights
The brand boasts that the Skoda Slavia will come with an emotive design language. The Skoda Slavia will also feature balanced proportions and a coupe-style silhouette. The first two design sketches reveal the vehicles front and the silhouette of the premium mid-size sedan. The Skoda Slavia comes with a low front section that features a wide, hexagonal SKODA grille. The grille extends all the way into the slender, sharply defined headlights. The headlights of the car come with L-shaped daytime running light strip. In addition to this, the car also features a coupe-style silhouette and a long wheelbase. The brand also offers a distinctive badge with the SKODA wordmark on the front wings.
The Skoda Slavia also reveals a progressive roofline that slopes gently towards the rear. The roofline gently merges into the rear deck of the vehicle integrating with the boot lid. In addition to this, the boot lid also features the SKODA wordmark in block letters. The car also features a chrome strip on the rear apron along with red reflectors to increase the nighttime visibility of the vehicle as well as the width. The rear end of the car also features Skoda's signature C-shaped light design, split into two to extend into the boot lid.
Skoda Slavia – Dimensions and Powertrain Details
In the recent past, Skoda revealed that the Slavia would measure 4,541 mm in length, 1,752 mm in width, and 1,487 mm in height. The Slavia will also come with a wheelbase of 2,651 mm, offering spacious interiors and boot space. The Skoda Slavia is likely to come with a 1.0-litre TSI three-cylinder petrol engine as well as a 1.5-litre four-cylinder TSI petrol engine on higher-specification models. Skoda will also offer the Slavia will active and passive safety features, including six airbags.
Also Read: Skoda Slavia Sedan for India – Dimensions & Specifications Revealed
Sedan Skoda Skoda Slavia Slavia
BMW Motorrad reveals new K 1600 touring range


On this website we recommend many pictures abaout succulent garden design that we have collected from various sites renatopolimeno.com, and of course what we recommend is the most excellent of picture for succulent garden design. If you like the picture on our website, please do not hesitate to visit again and get inspiration from our website.
And if you want to see more images more we recommend the gallery below, you can see the picture as a reference design from your succulent garden design.
Thank you for seeing gallery of succulent garden design, we would be very happy if you come back.
Similar Keyword succulent garden design : succulent garden design australia, succulent garden design images, succulent garden design nz, succulent garden design san diego, succulent garden design south africa, succulent garden design tips, succulent garden design youtube, succulent garden designer series paper, succulent garden designs pinterest, succulent garden ideas australia, succulent garden ideas images, succulent garden ideas nz, succulent garden ideas south africa, and more.


The Chabad On Campus in-depth Israel educational experience linking our Land, our People and our Heritage: IsraeLinks is a unique program offering deep and meaningful exploration of our Jewish heritage — Yesterday, Today & Tomorrow.
Three-week extensive guided tours of the country will be accompanied by stimulating lectures and discussions with academic and rabbinic experts.
Participants will get to review ancient and contemporary source materials, undertake exciting historical explorations, take part in mentored discussions of Judaism, as well as have a first-hand discovery of the social, religious, and political composition of the Holy Land.
IsraeLinks will provide participants with state-of-the-art tour buses, comfortable lodgings, delicious daily meals (including Shabbat), experienced English-speaking tour guides, fully paid entrance fees, and many extras which will make this once-in-a-lifetime trip to Israel cherished and memorable.
Only $499*, including airfare from New York and all trip costs (food, lodging & trips, minus occasional meals costs on your own).
*There is a fully refundable $150 security deposit that will be returned once the trip, and post trip survey is completed.


text:
How WCH is leveraging virtual care to address COVID-19
WCH CONNECT•April 8, 2020
BY Jordan Benadiba
The COVID-19 pandemic has forced the entire health system to re-think how we can deliver care. Leveraging our expertise and infrastructure as Canada's first virtual hospital, Women's College Hospital (WCH) has quickly adapted to respond to the needs of our community during this public health emergency. Our Women's Virtual team is working across the organization and with our partners across the health system to accelerate our virtual care capabilities to ensure that we can provide care safely for patients who need it.
Over the past few weeks, we have been able to convert many in-person visits to virtual visits. While all our clinics have shifted a large volume of care to phone visits, our Department of Mental Health, Cardiac Rehab Program and Sexual Assault/Domestic Violence Care Centre (SA/DVCC) are all utilizing video visits to enhance access and continuity of care for patients. "Prior to COVID-19, WCH averaged roughly 20 video visits per month, as it rolled-out this capability to providers. Within the month of March alone, WCH providers completed 240 video visits, a roughly ten-fold increase," said Laura Pus, administrative director of Women's Virtual. "The Women's Virtual team, IM/IT and others have been working tirelessly with providers across the hospital to covert as many visits as possible to virtual," Pus added. Over the next few weeks, additional WCH care teams will be enabled with video visits.
This shift towards virtual care has been particularly apparent in WCH's Family Practice Health Centre (FPHC). "In the face of this unprecedented pandemic, we're changing how we deliver our services, to keep our patients and staff as safe as possible - while continuing to provide care to those in need," explained Dr. Ruth Heisey, chief of family medicine at WCH. Within a two-week period, 80 per cent of patient visits at family practice were conducted virtually. "These changes will be in place for the foreseeable future. But they'll be influencing our models of care long after this pandemic has passed. It's clear we're all going to need to embrace our virtual capabilities, to help optimize care via video and phone consults and other virtual tools - bringing the care and comfort of a family physician's visit into the comfort and safety of a patient's home," Dr. Heisey said.
LTC+ Program
In response to COVID-19, we have fast-tracked our Women's Virtual LTC+ program to support our long-term care (LTC) colleagues who care for many frail older adults in Ontario. In the context of the COVID-19 pandemic, transfers to acute care pose greater risks to seniors living in LTC. LTC+ aims to deliver the best care possible to residents in the LTC setting to avoid unnecessary transfers to hospitals.
LTC+ is a virtual care program that connects LTC nursing staff and physicians with 24/7 virtual consultations with medical specialists for advice and consultation. It also provides the LTC team with access to other services, such as the availability of STAT labs and community paramedicine, that will enable the LTC team to provide high-quality care to residents in the LTC home setting and avoid unnecessary transfers to hospitals.
The program is enabled by cross-sector partnerships that brings together hospital and community based resources to support LTC residents. "As we all now know, seniors and those with compromised immune systems need to be particularly careful during this pandemic. Reducing unnecessary ED transfers is an important step towards protecting their health and reducing the spread of COVID-19," said Laura Pus. LTC+ is currently live with five long-term care facilities, over the next two weeks, WCH will expand this program to include all 37 LTC homes in the Toronto area.
COVID-19 Virtual Assessment Tool
Recognizing that responsive access to testing is critical during this pandemic, WCH has launched our own virtual assessment tool to support the efforts of our COVID-19 assessment centre. Found on our hospital website, the tool first screens people through a series of questions to determine the most appropriate pathway for patients. Individuals who meet the criteria for an assessment receive a virtual assessment with a WCH physician to determine if they require a nasopharyngeal swab. Patients requiring a swab are fast-tracked allowing them to come into the assessment centre and get swabbed right away. "If people do have COVID-19 symptoms, we want to make the assessment process as quick as possible for them to alleviate any fear or anxiety they may have and get them care as soon as possible," said Darryl Yates, vice president, patient care and ambulatory innovation. As of April 1, 4798 people have used our virtual assessment tool, 484 have received follow up calls and over 242 have been fast tracked through our assessment centre for care.
COVIDCare@Home
As demand on acute care resources including emergency departments and inpatient beds increase, most symptomatic yet stable patients will be required to monitor their COVID-19 symptoms at home. In response, WCH will shortly launch COVIDCare@Home, a virtual care initiative designed to support primary care providers as they care for patients at home with COVID-19. Working with our hospital partners, the Department of Family and Community Medicine at the University of Toronto, the SCOPE program and multiple WCH teams, COVIDCare@Home is building practical digital pathways and tools for primary care providers as they virtually support their patients with COVID-19. "Being able to monitor patients with COVID-19 virtually, not only allows us to ensure that everyone who needs care is receiving it, but should their health deteriorate, we are better positioned to act quickly and escalate their care," said Dr. Payal Agarwal, WCH family physician and co-process lead of COVIDCare@Home.
A virtual care hub, housed at WCH, COVIDCare@Home will share specific resources with providers enabling them to better address their patient's medical, mental health and social needs. It will also provide real-time support to primary care providers and patients, as well as enable virtual care through phone or video visits. COVIDCare@Home patients will also have access to the WCH AACU as needed, limiting the burden on acute care hospitals.
Through these multiple virtual care channels and tools, WCH is ensuring on-going care for existing patients, as well as directly responding to the COVID-19 pandemic. "In a relatively short period of time, our teams have quickly utilized digital health tools and new virtual models of care to address this emergency," said Dr. Danielle Martin, executive vice president and chief medical executive at WCH. "Everyone at WCH is going above and beyond to think outside the box to help care for our community and reduce health system pressure during this important time. It has been an incredible privilege to be a part of," Dr. Martin added.
More articles from this issue
April 8, 2020 Stress-relief playbook
April 8, 2020 Putting a crisis to work: COVID-19 can be the push we need to modernize our health-care system
April 8, 2020 Make sure your mask fit test is up-to-date
Our Latest Issue
Keep up to date with the latest from Women's College hospital.
Sign up for Connect.


text:
Vanda Pharmaceuticals cuts IPO price est. to $10
Published: Apr 12, 2006 7:31 a.m. ET
NEW YORK (MarketWatch) -- Vanda Pharmaceuticals VND, +0.35% said in a filing with regulators Wednesday that it expects its initial public offering to price at $10 a share, below its earlier range of $12-$14 a share. The Rockville, Md. company kept the size of the IPO at 5.75 million shares in a bid to raise about $58 milion in the deal. J.P. Morgan and Banc of America Securities are underwriting the IPO.
VNDirect Securities Corp. Ho Chi Minh Stock Exchange: VND
₫14,450.00
Open ₫14,450
High ₫14,450
Low ₫14,000