Any refund from your 2013 Federal income tax return is not taxable income to you for 2014 (or for any later year either), neither for Federal income tax nor for State or
local income tax purposes.
Desert Newco is currently, and will be through consummation of the Reorganization Transactions, treated as a partnership for U.S. federal and most applicable state and
local income tax purposes.
The Company is treated as a partnership for U.S. federal and most applicable state and
local income tax purposes.
Desert Newco is currently, and will through consummation of the reorganization transactions, be treated as a partnership for U.S. federal and most applicable state and
local income tax purposes.
Not exact matches
In all foreign countries except Canada, we operate through legal entities disregarded for U.S.
income tax purposes, and are subject to
income tax in both the
local country and the U.S. Unremitted earnings from our Canadian subsidiary, which are intended to be permanently reinvested outside the U.S., are not material.
Furthermore, we will calculate the state and
local income tax savings by applying this 5 % rate to the reduction in our taxable
income, as determined for U.S. federal
income tax purposes, as a result of the
tax attributes subject to the TRAs.
In all foreign countries except Canada, we operate through legal entities disregarded for U.S.
income tax purposes, and are subject to
income tax in both the
local country and the U.S. Unremitted earnings from our Canadian subsidiary, which we intend to permanently reinvest outside the U.S., are not material.
For
purposes of calculating the
income tax savings we are deemed to realize under the TRAs, we will calculate the U.S. federal
income tax savings using the actual applicable U.S. federal
income tax rate and will calculate the state and
local income tax savings using 5 % for the assumed combined state and
local rate, which represents an approximation of our combined state and
local income tax rate, net of federal
income tax benefit.
Since contributions would be both deductible and trigger the credit, the effective credit would be between 91 percent and 94 percent.31 This proposal provides relief from the SALT cap because the contribution can be deducted from
income for federal
tax purposes, just as the State and
local tax was prior to TCJA.
And in New Jersey, where
local property
taxes are a much bigger concern than state
income taxes,
incoming Democratic governor Phil Murphy and two Democratic congressmen have floated a proposal to create a charitable foundation similar to the one being contemplated for California and New York, but with property -
tax purposes targeted and a new state
tax credit created against property -
tax liability.
«I believe that it is important that the Treasury and the IRS issue guidance or a formal opinion letter whether taxpayer contributions to state authorized trust funds, partially reimbursed by credits reducing state and
local income taxes, will be considered deductible for federal
tax purposes,» Faso wrote in the letter.
In certain circumstances, the U.S. Internal Revenue Code requires that individual
income taxpayers report the refund of excess state or
local income tax payments received by the taxpayer as
income for federal
income tax purposes.
You can generally claim the same deductions for Virginia
purposes that you claimed on your federal Schedule A, except for the deduction for state and
local income taxes.
Real property
taxes, along with other state and
local taxes paid, are deductible for federal
income tax purposes.