Year-End Tax Update
November 1, 2023
CITRIN COOPERMAN
Agenda
2
1.
Introductions
2.
Recent Tax Changes – The Big 4 - Bonus Depreciation - §163(j) Business Interest Expense Limitation - §174 Research & Experimental Costs - Net Operating Loss/Excess Business Loss
3.
State Pass-Through Entity (PTE) Tax
4.
Future Considerations - Elements of the Secure Act - Qualified Opportunity Zone Deferrals - Tax Cuts and Jobs Act (TCJA) Sunsets
5.
Recent MA Tax Legislation and RI Updates
6.
Q&A
CITRIN COOPERMAN
Presenters
JOHN FINNERTY
Partner jfinnerty@citrincooperman.com
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SARAH BRAY
Senior sbray@citrincooperman.com
Recent Tax Changes CITRIN COOPERMAN
BONUS DEPRECIATION – PHASE-OUT
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Items that had delayed enactments dates from the Tax Cuts and Jobs Act (TCJA): The TCJA extended bonus depreciation rules that were set to expire at the end of 2019 and increased the deductible amount to 100% for assets placed in service after September 27, 2017, and before January 1, 2023. Unless the law changes, the bonus percentage will decrease by 20 points each year over the next few years until it eventually phases out completely:
Year
Bonus Depreciation Percentage Allowed
2022
100%
2023
80%
2024
60%
2025
40%
2026
20%
2027
0%
Recent Tax Changes CITRIN COOPERMAN
§163(J) BUSINESS INTEREST LIMITATION For tax years starting after 2021, the business interest limitation calculation is revised to reflect earnings before interest and taxes (EBIT) — thus disallowing the add-back of depreciation and amortization. This change in calculation will broaden the net of the interest expense limitation, likely affecting many entities that had narrowly escaped the limitation in earlier years. After Before Taxable Income
$
$
250,000
Adjustments: Interest Expense
300,000
300,000
Depreciation
800,000
-
Amortization
200,000
-
Adjusted Taxable Income
$
Business Interest expense Limitation %
5
250,000
1,550,000
$
30.00%
550,000 30.00%
Business Interest Expense Limitation
$
465,000
$
165,000
Business Interest Expense
$
300,000
$
300,000
Business Interest Expense Limitation
$
465,000
$
165,000
Excess Business Interest - NOT CURRENTLY DEDUCTIBLE
$
-
$
135,000
Recent Tax Changes §174 RESEARCH & EXPERIMENTAL COSTS
CITRIN COOPERMAN
On January 01, 2022, a provision of the TCJA took effect and altered the treatment of research and experimental (R&E) expenditures under Section 174 of the IRC (Sec. 174 expenses).
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Historically, businesses have had the option of deducting Sec. 174 expenses in the year incurred or capitalizing and amortizing the costs over 5 years. But under the new TCJA provision, taxpayers are required to capitalize and amortize these costs over five years for research conducted within the United States or 15 years for research conducted outside of the United States. Unlike the research and development (R&D) tax credit under IRC Section 41 (Sec. 41), Sec. 174 expenses include both direct and indirect R&D expenses, overhead expenses and all software development costs. Taxpayers may consider conducting an R&D tax credit study as a first step to identify 174 expenses and reduce the negative tax impact of Sec. 174 amortization.
Recent Tax Changes §174 RESEARCH & EXPERIMENTAL COSTS
CITRIN COOPERMAN
Interplay Between Sections 174 and 41:
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Expense Type
Section 174
Section 41
Wages
Yes (book wages)
Yes (W-2 taxable wages)
Non-Taxable Employee Benefits
Yes
No
Payroll Taxes
Yes
No
Supplies
Yes
Yes
Contract Research Expense
Yes (100%)
Yes (65%)
Utilities
Yes
No
Rent Expense
Yes
No
Patent Expense
Yes
No
Overhead/Indirect Expense
Yes
No
Land/Improvements to Land
No
No
Recent Tax Changes §174 RESEARCH & EXPERIMENTAL COSTS §174 R&E Costs:
$ 1,500,000
CITRIN COOPERMAN
Assume all R&E activities withinthe US, capitalize and amortize over 5 years:
Year 1 Year 2 Year 3 Year 4 Year 5 Year 6
Total
Book Income
150,000 300,000 300,000 300,000 300,000 150,000
$ 1,500,000
Impact on Taxable Income: Before $ 1,000,000
Other Book/Tax differences Addback §174 R&E Amortization of R&E
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$
After $ 1,000,000
300,000 -
300,000 1,500,000 (150,000)
Taxable Income Federal Tax Rate
$ 1,300,000 21.00%
$ 2,650,000 21.00%
Federal Tax
$
$
Increase in Tax
$
273,000 283,500
556,500
Recent Tax Changes CITRIN COOPERMAN
CONGRESSIONAL ACTION
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Recent Tax Changes EXCESS BUSINESS LOSSES
CITRIN COOPERMAN
Noncorporate taxpayers (individuals) cannot deduct excess business losses for tax years beginning after 12/31/20 and before 01/01/29. Instead, they must treat such losses as net operating losses (NOL) carryforward to the following tax year. Before applying the excess business loss rule, noncorporate taxpayers must apply: 1. Basis limitation rules; 2. The at-risk rules; and 3. The passive activity loss rules. The excess loss is also added back into income on the taxpayer’s individual income tax return, which in effect reduces the total loss shown on other parts of the return from the taxpayer’s businesses.
An “Excess Business Loss” is the excess, if any, of: 10
A Taxpayer’s aggregate deductions for the tax year from the taxpayer’s trade or businesses (without considering deductions disallowed from the excess business loss limitation)
The aggregate gross income or gain for the year from the trade or business
$289,000 ($578,000 for joint filing) *for 2023
Recent Tax Changes EXCESS BUSINESS LOSSES CASE 1
CITRIN COOPERMAN
Entities
CASE 2
Business Loss
$(1,000,000)
$(1,000,000)
Business Income
200,000
-
$ (800,000)
$(1,000,000)
EBL Floor Limitation*
$500,000
$500,000
Business Income + Floor Limitation
$700,000
$500,000
Remaining Loss Attributable to Activity A
300,000
500,000
Tax Return Components
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A
$(700,000)
$(500,000)
B
200,000
-
Net Deductible Business Loss
$(500,000)
$(500,000)
(300,000)
(500,000)
$(800,000)
$(1,000,000)
Carryforward
Converted to an NOL Subtotal
*Limitation for MFJ is $578,000. Using round numbers for simplicity.
Recent Tax Changes NET OPERATING LOSS
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An NOL is the excess of a business’s tax deductions for the tax year over its taxable income for that year. Depending on the year generated, the Net Operating Loss (NOL) will be treated as follows:
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Pre-2018:
NOL can be carried back 2 years & carried forward 20 years (up to 100% of taxable income).
CARES Act (2020):
NOL from a tax year beginning in 2018, 2019 or 2020 can be carried back 5 years. NOL’s do not need to be carried back, however, if the carryback period is elected, the NOL must be carried back the full 5 years. Unlimited NOL carryforward. Can be utilized up to 100% of taxable income.
Post 2020
No NOL carryback, unlimited NOL carryforward. Can only offset 80% of taxable income in a year.
Recent Tax Changes CITRIN COOPERMAN
NET OPERATING LOSS
13
Post2020 NOL deduction
1
Pre-2018 NOL carryforwards
Post-2017 NOL carryforwards
Lesser of:
OR
2
Modified taxable income*
80%
Pre-2018 NOL carryforwards
Example: Taxpayer has pre-2018 NOL carryforwards of $200,000, post-2017 NOL carryforwards of $800,000 and modified taxable income of $1,000,000.
$800,000
NOL Deduction
$200,000
$840,000
$200,000
Lesser of:
80%
OR
$1,000,000
$200,000
$640,000
*Taxable income computed without regard to the deductions under Qualified Business Income (QBI), Net Operating Losses (NOLs), and Foreign-Derived Intangible Income (FDII).
State Pass-Through Entity Tax CITRIN COOPERMAN
HISTORY: The TCJA limits provided for an annual limitation on the amount of state and local taxes individuals can deduct for federal income tax purposes to not more than $10,000 ($5,000 in the case of a married individual filing a separate return) (the SALT cap). Note that the limitation includes state taxes, real estate taxes and personal property taxes. States became concerned and began to offer taxpayers a "workaround" to the SALT cap by enacting passthrough-entitylevel taxes, which arguably impose the tax liability for owners of passthrough entities (PTEs) (such as partnerships, LLCs treated as partnerships, and S corporations) instead directly on the PTE. These new state PTE taxes essentially allow owners of PTEs to bypass the SALT cap by allowing their distributive share of the taxes to be paid by the entity at the entity level, as reported on their respective Forms K-1, since one exception to the SALT cap was the retention of the "trade or business" exception. Additionally, individual owners can generally claim a proportionate share of the PTE tax paid as a credit against their state tax liability – thus avoiding paying state tax on the same income.
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State Pass-Through Entity Tax
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State Pass-Through Entity Tax
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State Pass-Through Entity Tax Entity Level Without PTE
CITRIN COOPERMAN
Gross Income
$ 10,000,000
$ 10,000,000
(7,000,000) -
(7,000,000) (179,700)
Expenses PTE Deduction Federal Taxable Income
$
3,000,000
$ 2,820,300
State Taxable Income
$
3,000,000
$ 2,820,300
Addback State PTE Adjusted State Taxable Income State PTE Tax rate State PTE Tax
17
With PTE
-
179,700
3,000,000
3,000,000 5.99%
N/A N/A
$
179,700
State Pass-Through Entity Tax CITRIN COOPERMAN
Federal Flowthrough Income
Shareholder Level Without PTE
With PTE
$ 3,000,000
$ 2,820,300
30.00%
30.00%
Assumed Tax Rate Federal Tax
$
$
846,090
$ 53,910 Federal Tax Savings State Taxable Income
$ 3,000,000
$ 3,000,000
5.99%
5.99%
179,700
179,700
N/A
(179,700)
State Tax Rate State Tax State PTE Credit Tax Due with Retun 18
900,000
$
179,700
$
-
Future Considerations CITRIN COOPERMAN
ELEMENTS OF THE SECURE ACT
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On December 29, 2022, President Biden signed the Consolidated Appropriations Act, 2023, which is wrapped into the larger bill, Securing a Strong Retirement Act, commonly called SECURE Act 2.0. This package of laws follows the Setting Every Community Up for Retirement Enhancement (SECURE) Act signed into law at the end of 2019. SECURE Act 2.0 covers numerous changes to retirement provisions designed to increase retirement savings, facilitate access to retirement savings, encourage employees to save for retirement, and lower employers’ cost of offering and funding retirement savings plans. The majority of the SECURE 2.0 provisions will become effective in 2024. Provisions Impacting All Employers: • Mandatory Participation: For plan years beginning after December 31, 2024, an employer with more than 10 employees who have been in existence for at least three years and who is offering a new 401(k) or 403(b) plan, must provide automatic enrollment for new employees and automatic escalation of the amount of an employee’s deferral. Under these rules, new employees will start with a salary reduction of at least 3% of compensation. The rate of salary reduction increases annually by 1% of compensation until reaching at least 10%, but no more than 15%. An employee may elect out of auto-enrollment and/or auto escalations.
Future Considerations CITRIN COOPERMAN
ELEMENTS OF THE SECURE ACT
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Provisions Impacting All Employers: • Roth Accounts: Designated Roth accounts in employer plans are encouraged under the new law. Roth accounts within 401(k) plans, 403(b) plans and 457 plans are no longer subject to required minimum distribution (RMD) rules. This provision puts Roth accounts on par with Roth IRAs. Prior to SECURE Act 2.0, employees had to transfer their Roth accounts from the employer plan to a Roth IRA to escape RMDs. Now employees can continue to compound earnings tax-free after retirement within their employer’s plan. •
Part-Time Employee Eligibility: Part-time employees were encouraged to participate in employer plans under provisions in the first SECURE Act. In 2019 the tax law changed to require plans to allow long-term, part-time employees to be eligible for an employer’s 401(k) plan. SECURE (2019) permitted dual eligibility for plans: one year of service of 1,000 hours or three consecutive years of service of 500 hours. Under SECURE Act 2.0, part-time employees are eligible to participate in an employer’s 401(k) plan or 403(b) plan with two consecutive years of service of 500 hours. For transition purposes, pre-2021 service of part-time employees is disregarded for vesting and eligibility under this new rule.
Future Considerations CITRIN COOPERMAN
ELEMENTS OF THE SECURE ACT Provisions Impacting All Employers: • New RMD Start Date: SECURE 2.0 pushes back the beginning date for required minimum distributions from qualified plans. Individuals turning age 72 during 2023 or later will start their RMD at age 73. For those reaching age 74 after December 31, 2032, their start date is age 75. For those able to defer their RMD to these later birthdays, retirement savings may continue to compound earnings tax-deferred or tax-exempt in the case of inherited Roth IRAs Required beginning date for individuals who: Attain age 72 after December 31, 2022 = age 73 Attain age 74 after December 31, 2032 = age 75 Generally applies to distributions required to be made after December 31, 2022, with respect to individuals who attain age 72 after such date •
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RMD Penalty Relief: If required minimum distributions are not taken, the excise tax penalty is reduced to 25% <previously 50%> for taxable years beginning in 2023. The penalty is further reduced to 10% if correction is made within two years after the end of the taxable year in which the distribution was missed.
Future Considerations CITRIN COOPERMAN
ELEMENTS OF THE SECURE ACT Provisions Impacting All Employers: • Catch-up Contributions: Individuals over age 50 can contribute a salary reduction catch-up contribution to an employer plan. This contribution is currently limited to $6,500 annually. For tax years beginning after 2024, employees who are 60-63 years old can take advantage of a higher catch-up contribution of $10,000. SECURE Act 2.0 provisions also index the IRA catch-up contribution for individuals over age 50. The current catchup amount is $1,000, but this amount will increase for cost-of-living adjustments in tax years beginning after 2023. SECURE 2.0 requires that catch-up contributions are designated as Roth contributions for any plan participant whose wages exceed $145,000, effective for tax years after 2023. In addition, employers can make matching and non-elective contributions to designated Roth accounts Other Provision categories (not detailed herein): • Encouraging Small Employers To Establish Retirement Savings Plans • College Loans and Savings • Emergency Savings and Distributions
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Future Considerations ELEMENTS OF THE SECURE ACT
CITRIN COOPERMAN
Catch-up Contributions – Updated: The IRS guidance makes the following announcements: • Enforcement of the Roth catch-up contribution provision for high-paid employees (defined as employees with wages of more than $145,000 in the prior year) is delayed until January 1, 2026. •
Age-based catch-up contributions will continue to be available after 2023. There had been some concern that a drafting error in the SECURE 2.0 Act inadvertently eliminated catch-up contributions.
•
If an employee makes elective deferrals to two or more plans during a year, those deferrals are aggregated for purposes of both the annual limit on elective deferrals ($22,500 for 2023) and the catch-up contribution limit ($7,500 for 2023).
•
The U.S. Treasury Department and the IRS expect to issue further guidance on the Roth catch-up contribution provision, including guidance on the following topics: -
Clarification that the Roth catch-up contribution provision would not apply to individuals who do not have wages for FICA purposes (e.g., partners and self-employed individuals, including self-employed clergy).
-
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Guidance indicating that a plan administrator would be permitted to treat a high-paid employee’s election to make pre-tax catch-up contributions as a deemed election to make catch-up contributions on a Roth after-tax basis.
-
Guidance for multi-employer plans and multiple-employer plans in applying the Roth catch-up contribution provision.
Future Considerations CITRIN COOPERMAN
QUALIFIED OPPORTUNITY ZONE DEFERRAL What is an Opportunity Zone? An Opportunity Zone is a community nominated by the state and certified by the Treasury Department as qualifying for this program. The Treasury Department has certified zones in all 50 states; Washington, D.C.; and U.S. territories. There are approximately 8,700 Opportunity Zones nationwide. How does this program work? To defer a capital gain (including net §1231 gains), a taxpayer has 180 days from the date of the sale or exchange of appreciated property to invest the realized capital gain dollars into a Qualified Opportunity Fund. The fund then invests in Qualified Opportunity Zone property. Note that a taxpayer who receives a reported capital gain from a flow-through entity, such as a partnership, an Scorporation, or a trust/estate, has 180 days from the end of the calendar year to make an investment in a Qualified Opportunity Fund, regardless of how early in the calendar year the entity itself realized its gain. For example, if a partnership entity realized a capital gain in March, each partner’s 180-day triggering date will be December 31 of the same year and each partner will have until approximately June 28 of the following year to make their Qualified Opportunity Zone investment. 24
Future Considerations QUALIFIED OPPORTUNITY ZONE DEFERRAL
CITRIN COOPERMAN
Tax deferral and savings A Qualified Opportunity Fund investment provides potential tax savings in three ways:
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1.
Tax deferral through 2026 - A taxpayer may elect to defer the tax on some or all of a capital gain if, during the 180day period beginning at the date of sale/exchange, they invest in a Qualified Opportunity Fund. Any taxable gain invested in a Qualified Opportunity Fund is not recognized until December 31, 2026 (due with the filing of the 2026 return in 2027), or until the interest in the fund is sold or exchanged, whichever occurs first. In addition, the deferred gain can be further reduced as described below.
2.
Step-up in tax basis of 10% or up to 15% of deferred gains - A taxpayer who defers gains through a Qualified Opportunity Fund investment receives a 10% step-up in tax basis after five years and an additional 5% step-up after seven years. Note that to take full advantage of the 15% step-up in tax basis, the taxpayer must have invested by December 31, 2019. When the tax is triggered at the end of 2026, the taxpayer will have held the investment in the fund for seven years, thereby qualifying for the 15% increase in tax basis.
3.
No tax on appreciation - Remaining in the Qualified Opportunity Fund for at least 10 years results in the cost basis of the property being equal to the fair market value on the date of sale/exchange.
Future Considerations CITRIN COOPERMAN
TAX CUTS AND JOBS ACT (TCJA) SUNSETS The TCJA made substantial changes to the tax code. In order to comply with certain budgetary constraints, the TCJA contains a “sunset,” or an expiration date, for many of its provisions. Accordingly, many of the TCJA expiration provisions are temporary. Unless otherwise noted, the TCJA expiration provisions discussed below are effective in 2018 and sunset after 2025. Comparison of key tax provisions Provision
2023
Post-TCJA Expiration
Individual Tax Rates
10%, 12%, 22%, 24%, 32%, 35% & 37%
10%, 15%, 25%, 28%, 33%, 35% & 39.6%
Standard deduction
$13,850 for individuals, $27,700 for couples
Reduced roughly in half; prior to TCJA, the standard deduction was $6,350 for individuals, $12,700 for couples
Capped at a maximum of $10,000
No cap applies, deductions phaseout at higher income levels due to the Pease limitation (phaseout begins at $261,500 for individuals, $313,800 for couples)
State and local tax deduction (SALT)
26
Mortgage interest deduction
Limited to interest on $750,000 of qualified debt
Miscellaneous deductions
Not available
Limited to interest on $1,000,000 of qualified debt and an additional $100,000 of qualified home equity interest debt Applicable once deductions exceed 2% of AGI; examples include investment fees, job search expenses, uniforms, unreimbursed work-related expenses
Future Considerations TAX CUTS AND JOBS ACT (TCJA) SUNSETS Comparison of key tax provisions
CITRIN COOPERMAN
Provision
27
2023
Post-TCJA Expiration
Not available
$4,050 per taxpayer and qualified dependents; phaseout at higher income levels begins at $261,500 for individuals, $313,800 for couples
Child Tax Credit
$2,000 per qualifying child (under age 17); $500 for other dependents; phaseout begins at $200,000 for individuals, $400,000 for couples
$1,000 per qualifying child with income phaseouts beginning at $75,000 for individuals, $110,000 for couples
Alternative Minimum Tax (AMT)
Applies to relatively few taxpayers given high exemption amounts ($81,300 for individuals, $126,500 for couples) and income phaseout amounts ($578,150 for individuals, $1,156,300 for couples)
AMT would apply to significantly more taxpayers due to much lower exemption and income phaseout amounts
Deduction for Qualified Business Income (QBI)
20% deduction applicable for pass-through businesses depending on circumstances
Not available
Unified lifetime exclusion amount is $12,920,000 per individual
Unified lifetime exclusion amount reduced roughly by half
Personal exemptions
Estate and gift tax
Future Considerations TAX CUTS AND JOBS ACT (TCJA) SUNSETS Comparison of key tax provisions
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Provision Employer Credit for Paid Family & Medical Leave
Post-TCJA Expiration Not Available
40% of up to $6,000 of wages paid to, or incurred on behalf of an individual who meets certain requirements
Not Available
Global Intangible Low-Taxed Income (GILTI)
Inclusion rate of 10.5%
Inclusion rate of 13.125%
Foreign-Derived Intangible Income (FDII)
Deduction rate of 37.5%; Effective tax rate of 13.125%
Deduction rate of 21.875%; Effective tax rate of 16.4%
Employer reimbursements are included in income & there is no deduction (exceptions for members of Armed Forces)
Employer reimbursements are included in income (unless qualified) & travelling & transporting expenses are deductible
Work Opportunity Credit
Moving Expenses 28
2023 12.5% of wages paid to a qualifying employee while on family & medical leave for up to 12 weeks per year, additions may apply
CITRIN COOPERMAN
Recent MA Tax Legislation
29
Select Provisions
Summary
Effective
Single Sales Factor Apportionment
Replaces the three-factor apportionment formula for determining tax liability from business activities in and outside the state with a single-factor apportionment formula based only on sales
beginning with the 2025 tax year
Short-Term Capital Gains Rate
Reduces the short-term capital gains rate for individuals from 12% to 8.5%
01.01.23
The tax threshold for the estate tax is increased from the current $1 million to $2 million. ___________________________________________________________ Estate tax
Eliminates the “cliff effect” present under the previous law. The new Act eliminates this cliff by providing a tax credit that is designed to cover the first $2,000,000 of the taxable estate. The result should be that a taxable estate valued at $2,000,000 or less after deductions should not pay any Massachusetts estate tax at all and that a taxable estate valued at more than $2,000,000 would pay Massachusetts estate tax only on the excess.
01.01.23
Millionaire's tax loophole closed
The law requires married couples that file a joint federal tax return to also file a joint return for their MA state taxes, closing a potential loophole that could allow married filers to file separately and avoid the 4% surtax on their aggregate income over $1 million
01.01.24
Rental Deduction
increases the cap on the residential rent deduction from $3,000 to $4,000
01.01.23
Recent RI Tax Update Select Provisions
CITRIN COOPERMAN
Electronic Filing Mandate
Estate Tax – Credit & Threshold
Tax Credits Extended
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Summary Larger business registrant taxpayers are required to use electronic means to file returns and remit taxes to the State of Rhode Island beginning on January 1, 2023. A "larger business registrant" is defined as any person who: • Operates as a business whose combined annual liability for all taxes administered by the Division of Taxation for the entity is or exceeds $5,000; or • Operated as a business whose annual gross income is over $100,000 for the entity.
Effective
01.01.23
01.01.23
01.01.23
Recent RI Tax Update
31
Pass-through tax form changes
CITRIN COOPERMAN
Select Provisions
Summary Adv 2022-27: The Rhode Island Division of Taxation will be discontinuing the use of the RI-1096PT form series for tax year 2023. The addition of a schedule to the various entity returns will replace the RI-1096PT form series and streamline filing requirements for both taxpayers and tax preparers. The RI-1096PT-ES will no longer be used for making estimated payments starting in January 2023
The larger change will come in 2024. Beginning in calendar year 2024 for tax year 2023 returns, taxpayers will no longer file the RI-1096PT as a stand-alone tax return. Instead, the Division will be adding a new schedule to entity tax returns For tax year 2024, the Division will be continuing its modernization efforts by also transitioning the RI-PTE series of forms into schedules on entity level returns.
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