Tax Reform 2017: What You Need to Know

Table of Contents
Corporate and Business. 2
Individuals. 7
Estate/ Gift Tax. 12
Charitable Contributions/ Non Profits. 13
Other. 14
Real Estate. 14
Depreciation. 14

2017 Tax Reform

On December 22, 2017, President Trump signed the bill previously known as the Tax Cuts and Jobs Act into law.  The final bill removed the name “Tax Cuts and Jobs Act” and replaced it with “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018” (which for purposes of this summary we refer to as the “Act”).

This article is a high level overview of key provisions of the Act which are likely to impact our clients.

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To see the Act in its entirety please visit:

https://waysandmeansforms.house.gov/uploadedfiles/bill_text.pdf

Corporate and Business

  • Corporate Tax Rate

    • Beginning in 2018, reduces the corporate tax rate to 21% flat rate; which also applies to personal service corporations. The new law generally also reduces the dividends received deduction from 80% to 65% for dividends received when the corporation receiving the dividend owns 20% or more of the corporation distributing the dividend, and from 70% to 50% for dividends received when the corporation receiving the dividend owns less than 20% of the corporation distributing the dividend. The maximum corporate tax rate on net capital gain is repealed.
  • Alternative Minimum Tax for Corporations (AMT)
    • Beginning in 2018, corporate AMT is repealed; however, prior year minimum tax credits are allowed to offset the taxpayer’s regular tax liability for any tax year. For tax years beginning after 2018 through tax years beginning before 2023, the prior year minimum tax credit is refundable equal to 50% (or 100% after 2022) of the excess of the credit for the tax year over the amount of the credit allowable for the year against regular tax liability.
  • S Corporation Conversion to C Corporation
    • Any change in accounting adjustment under Section 481(a) attributable to the revocation of an S corporation’s election (i.e., generally adjustments required from changing from the cash method to the accrual method of accounting) are taken into account ratably over a 6-tax year period beginning with the year of accounting change for certain eligible S corporations. S corporations are eligible if they revoke their S corporation elections during the two-year period beginning on the enactment date of the Tax Reform Act and have the same owners on both Tax Reform Act’s enactment date and date the S election is revoked.
  • Pass-Through Tax Treatment
    • Beginning January 1, 2018 and continuing until December 21, 2025, the Tax Reform Act allows a new deduction for taxpayers who have domestic “qualified business income” (QBI) from a partnership, S corporation, or sole proprietorship. While this new deduction will likely benefit many small businesses, the calculation is complex.
      • Step #1:  Determine the deductible amount for each QBT (qualified trade or business) as follows:
        • The deductible amount for each QBT is the lesser of:
          • 20% of the income related to that QBT allocated to the taxpayer; or
          • the greater of:
            • 50% of the W-2 wages with respect to the QBT allocated to the taxpayer; or
            • the sum of 25% of the W-2 wages and 2.5% of the unadjusted basis, immediately after acquisition, of all qualified property allocated to the taxpayer.
      • Step #2:  The taxpayer’s deductible amount is equal to the lesser of the following amounts:
        • The taxpayer’s CQBIA (combined qualified income amount), or the sum of the following:
          • The deductible amounts for each QBT (qualified trade or business) determined in step #1 above, and
          • 20% of the taxpayer’s qualified REIT (real-estate investment trust) dividends.
        • 20% of the taxpayer’s taxable income over any net capital gain.
      • For purposes of the calculations, the following special rules apply:
        • QBI (income of a qualified trade or business) includes all domestic business income other than investment income (e.g., dividends), investment interest income, short-term capital gains, long-term capital gains, commodities gains, foreign currency gains, etc.
        • The wage limitation in Step #1, calculating the deductible amount for each QBT (qualified trade or business) will not apply for taxpayers if their taxable income is less than $157,500 for single and $315,000 for married filing joint taxpayers.A qualified business eligible for the deduction does not include a specified service trade or business, meaning any trade or business involving the performance of services in the fields of health, law, consulting, athletics, financial services, brokerage services, or any trade or business where the principal asset of such trade or business is the reputation or skill of one or more of its employees or owners, or which involves the performance of services that consist of investing and investment management trading, or dealing in securities, partnership interests, or commodities.  A service business does NOT include engineering or architectural businesses.  Notwithstanding this prohibition, a qualified business income deduction is allowed for taxpayers with a service business if their taxable income is less than $157,500 for single and $315,000 for married filing joint taxpayers; however, the deduction amount is phased out for taxpayers to the extent that income exceeds $50,000 for single and $100,000 for joint filers. Lastly, the 20% deduction is not allowed in computing adjusted gross income, rather the 20% deduction is allowed as a deduction reducing taxable income, and is available for both itemizers and non-itemizers.
  • Technical Termination of Partnership
    • Under the prior law if 50% or more of the interests in a partnership were transferred in a tax year, the partnership was deemed to have technically terminated for income tax purposes. Starting in 2018, the technical termination rule is repealed and a partnership will continue, without election, even if more than 50% of the total capital and profit interest of partnership were sold or exchanged in a tax year.
  • Expansion of Qualifying Beneficiaries of an Electing Small Business Trust (ESBT)
    • Effective Jan. 1, 2018, a nonresident alien could be a potential current beneficiary of an Electing Small Business Trust, which is a permitted S Corporation shareholder.
  • Basis Limitation on Partner Losses
    • For partnership taxable years beginning after December 31, 2017, the basis limitation on the deductibility of partner losses would also apply to a partner’s distributive share of charitable contributions. However, basis limitation would not apply to the excess of fair market value over adjusted basis on charitable contributions of appreciated property by the partnership.
  • Carried Interest Holding Period Holding Period
    • After 2017, transfers of any applicable partnership interests held for less than three years are treated as a short-term capital gain; notwithstanding the rules of section 83 or any election in effect under section 83(b). However, certain equity interests are exempt. Note, the fact that an individual may have included an amount in income upon acquisition of the applicable partnership interest, or that an individual may have made a section 83(b) election with respect to an applicable partnership interest, will not change the three-year holding period requirement for long-term capital gain treatment with respect to the applicable partnership interest under this provision.
  • Substantial Built-in Loss for Partnership for Partnerships
    • In general, a partnership cannot adjust the basis of partnership property following a transfer of a partnership interest unless the partnership has made either a special one-time election to adjust the property’s basis or the partnership has a “substantial” built in loss immediately after the transfer (adjustments are then made to both the transferee’s interest in the partnership property and the transferees share in the partnership property). Under the old law, a substantial built-in loss only existed if the partnership’s adjusted basis in its property is greater than $250,000 of the fair market value of the partnership property. Under the new law, the definition of what constitutes a substantial built-in loss is slightly expanded, a partnership can also make a basis adjustment for a substantial built-in loss if in a hypothetical disposition by the partnership of all partnership’s assets in a fully taxable transaction for cash equal to the assets’ fair market value will result in the transferee being allocated a net loss upon such hypothetical disposition in excess of $250,000 immediately after the hypothetical sale. The new law applies to transfers of partnership interests after December 31, 2017.
  • Limitation on Business Interest Expense Deduction
    • Generally, under the old law, business interest was allowed as a deduction in the tax year which the interest was paid or accrued (subject to certain limitations).  The new law limits the deduction for net interest expenses incurred by a business (with average annual gross receipts greater than $25 million) to the sum of: 30% of the business’s adjusted taxable income; business interest income; and floor plan financing interest. The amount of any business interest disallowed as a deduction for any taxable year (as a result of the limitation described above) will be treated as business interest paid or accrued in the succeeding taxable year and allowed to be carried forward indefinitely.
  • Net Operating Loss (“NOL”) Deduction
    • Beginning after December 31, 2017, taxpayers can generally deduct only 80% of NOL from the taxpayer’s taxable income (determined without regard to the deduction) and amounts carried forward to other years are adjusted to account for the limitation. Generally, the bill would generally repeal the allowance of carrybacks, except for farming NOLs, and NOLs can be carried forward indefinitely.
  • Employer Credit for Paid Family and Medical Leave
    • For wages paid in tax years beginning after December 31, 2017, eligible employers (which allow qualifying full-time employees at least two weeks of annual paid family and medical leave and a pro-rata amount of leave for part-time employees) can claim a business credit for 12.5% of the wages paid to qualifying employees during the leave period if the payment equals 50% of the wages normally paid to an employee. The credit is increased by 0.25% (but not above 25%) for each percentage point the payment to the employee exceeds 50% of normal wages.
  • Rehabilitation Credit
    • A 20% credit (claimed ratably over a five-year time period beginning in the tax year the structure is placed in service) for qualified rehabilitation expenditures for amounts paid or incurred after December 31, 2017 and a transition rule for specifically qualified buildings (allowing a deferral of the new credit rules for certain properties).
  • Entertainment, etc. Expenses
    • Generally, for amounts incurred after December 31, 2017, no deduction allowed for entertainment, amusement, or recreation; membership dues for a club organized for business, pleasure, recreation, or other social purposes; and no deduction allowed for entertainment, amusement, or recreation that is directly related to the taxpayer’s trade or business.  The deduction for 50% of food and beverage expenses related to a taxpayer’s trade or business is generally retained.
  • Local Lobbying Expenses
    • Eliminates the deduction for lobbying expenses regarding legislation before local government bodies, including Indian tribal governments, effective for amounts paid or incurred on or after December 22, 2017.
  • Expensing Costs of Replanting Citrus Plants
    • Allows a minority co-owner to deduct the replanting costs for citrus plants lost or damaged due to freezing temperatures, pests, disease, droughts, or casualty if certain requirements are satisfied.
  • Accounting for Long Term Contracts
    • For contracts entered into after 2017, increases the average gross receipts exception to $25 million (currently $10 million) for using the percentage-of-completion accounting method for long-term contracts to be completed within two years.
  • Other Accounting Methods
    • Effective for tax years beginning after December 31, 2017, requires a taxpayer to recognize income no later than the tax year in which such income is taken into account as income on the taxpayer’s financial statement, with an exception for any item of income for which a special method of accounting is used (other than the special methods of accounting for bonds and other debt instruments contained in §1271- §1288).

Individuals

  • Alternative Minimum Tax for Individuals
    • Temporarily increases both the exemption amount and the exemption amount phaseout thresholds for the individual AMT.  For taxable years beginning after December 31, 2017, and beginning before January 1, 2026, the AMT exemption amount is increased to $109,400 for married taxpayers filing a joint return (half this amount for married taxpayers filing a separate return), and $70,300 for all other taxpayers (other than estates and trusts).  The phaseout thresholds are increased to $1,000,000 for married taxpayers filing a joint return, and $500,000 for all other taxpayers (other than estates and trusts).  Amounts will be indexed for inflation.
  • Recharacterization of Certain IRA and Roth IRA Contributions
    • Generally, repeals the special rule that allows IRA contributions to one type of IRA (either traditional or Roth) to be recharacterized as a contribution to the other type of IRA.  The special rule that allows a contribution to one type of IRA to be recharacterized as a contribution to the other type of IRA will not apply to a conversion contribution to a Roth IRA and therefore recharacterization cannot be used to unwind a Roth conversion.  However, recharacterization is still permitted with respect to other contributions (i.e., an individual may make a contribution for a year to a Roth IRA and, before the due date for the individual’s income tax return for that year, and recharacterize it as a contribution to a traditional IRA.)
  • Standard Deduction
    • Effective for tax years beginning after December 31, 2017, increases the standard deduction to: $24,000 (joint return or a surviving spouse); $18,000 (unmarried individual with at least one qualifying child); $12,000 (for single filers).  The increased standard deduction amounts expire after December 31, 2025.
  • Personal Exemptions
    • Suspends the deduction for personal exemptions for tax years beginning after December 31, 2017, and before January 1, 2026.
  • Miscellaneous Itemized Deductions – 2 Percent Floor
    • Suspends all miscellaneous itemized deductions that are subject to the 2% floor under the current law for tax years beginning after December 31, 2017, and before January 1, 2026. For example, this includes: tax preparation costs; job related automobile expenses; expenses attributable to the trade or business of performing services as an employee; etc.
  • Limitation on Itemized Deductions
    • Under the prior law, the total amount of otherwise allowable itemized deductions (other than medical expenses, investment interest, and casualty, theft, or wagering losses) were limited for certain upper-income taxpayers (generally reducing the amount of the itemized deductions by 3% of the amount which the taxpayers adjusted income exceeded a set threshold amount). The new law suspends the overall limitation on itemized deductions for tax years beginning after December 31, 2017, and before January 1, 2026.
  • Charitable Contributions
    • For contributions made in years beginning after 2017 and before 2026, increases the AGI limitation on cash contributions from 50% to 60%, and repeals the current 80% deduction for contributions made for university athletic seating rights. Requires a contemporaneous written acknowledgement (i.e., a receipt) for contributions of less than $250, effective for contributions made in tax years beginning after December 31, 2016.
  • State and Local Tax Deduction
    • Generally, for individual taxpayers, state, local, and foreign property taxes and state and local sales taxes are allowed as a deduction only when paid or accrued in carrying on a trade or business, or relating to expenses for the production of income. Generally, individual state and local income taxes are not allowable as a deduction, however, a taxpayer may claim an itemized deduction of up to $10,000 ($5,000 for married taxpayer filing a separate return) for the aggregate of (i) state and local property taxes not paid or accrued in carrying on a trade or business, or an activity described in section 212, and (ii) state and local income taxes (or sales taxes in lieu of income, etc. taxes) paid or accrued in the taxable year. Note, foreign real property taxes are not deducted. Applies to taxable years beginning after December 31, 2017, and before January 1, 2026.
  • Affordable Care Act Individual Mandate
    • Effective for months beginning after December 31, 2018, reduces the amount of the individual shared responsibility payment enacted as part of the Affordable Care Act to zero.
  • Medical Expense Deduction
    • For taxable years beginning after December 31, 2016 and ending before January 1, 2019, the threshold for deducting medical expenses is 7.5% for all taxpayers for purposes of AMT and regular tax.
  • Alimony Payments Deduction
    • Effective for divorce decrees, separation agreements and certain other modifications entered into after December 31, 2018 eliminates the current above-the-line deduction for alimony payments and does not require the payee receiving alimony payments to include alimony payments into income. This applied regardless of the parties’ agreement otherwise.
  • Limitation on Losses for Taxpayers Other than Corporations
    • Beginning January 1, 2018 and ending December 31, 2025, business losses for individuals is limited to the loss generated from the taxpayer’s trade or business plus a threshold amount (generally, $500,000 for married taxpayers filing jointly or $250,000 for all other taxpayers). Losses in excess of this amount are disallowed as an excess business loss and added to the taxpayer’s NOL carryover for the following year.
  • Personal Casualty Losses Deduction
    • Personal casualty loss which arose after December 31, 2015 and before January 1, 2018 in a disaster area and was attributable to the events giving rise to the Presidential disaster declaration, such losses are deductible without regard to whether aggregate net losses exceed 10% of a taxpayer’s adjusted gross income. The losses must exceed $500 per casualty. Such losses may be claimed in addition to the standard deduction.
  • Moving Expenses Deduction
    • Generally, suspends the deduction for moving expenses for tax years beginning after December 31, 2017, and before January 1, 2026, with an exception for active duty members of the Armed Forces who move pursuant to a military order and incident to a permanent change of station.
  • Exclusion for Qualified Moving Expense Reimbursements
    • For tax years beginning after December 31, 2017 and before January 1, 2026, suspends the exclusion from gross income for qualified moving expense reimbursements, with an exception for active duty members of the Armed Forces who move pursuant to a military order and incident to a permanent change of station.
  • Enhancement of Child Tax Credit and New Family Tax Credit
    • Temporarily increases the child tax credit to $2,000 per qualifying child and temporarily provides for a $500 nonrefundable credit for qualifying dependents other than qualifying children. The maximum amount refundable may not exceed $1,400 per qualifying child and begins to phase out for taxpayers with adjusted gross income in excess of $400,000 (in the case of married taxpayers filing a joint return) and $200,000 (for all other taxpayers). The provision is effective beginning after December 31, 2017 and expires for taxable years beginning after December 31, 2025.
  • Reforms to Discharge of Certain Student Loan Indebtedness
    • Excludes from taxable income, income resulting from the discharge of certain student debt on account of the death or total and permanent disability of the student, effective for loans discharged after December 31, 2017.
  • Consolidation of Education Savings Rules
    • Allows section 529 plans to distribute not more than $10,000 in expenses for tuition incurred during the taxable year in connection with the enrollment or attendance of the designated beneficiary at a public, private or religious elementary or secondary school. An unborn child may qualify as a designated beneficiary for contributions made after December 31, 2017. The $10,000 limitation applies on a per-student basis, rather than a per-account basis (i.e., multiple Section 529 accounts can only give a total of $10,000 to one student in aggregate).

Individual Tax Rates

Current 2017 Rates Tax Reform Bill
The bill has seven tax brackets: 10%, 12%, 22%, 24%, 32%, 35%, and 37%. These brackets will apply to tax years beginning after December 31, 2017, and before January 1, 2026.
Married Filing Jointly (Surviving Spouses):

10% (Taxable income not over $18,550)

15% (Over $18,550 but not over $75,900)

25% (Over $75,900 but not over $153,100)

28% (Over $153,100 but not over $233,350)

33% (Over $233,350 but not over $416,700)

35% (Over $416,700 but not over 470,700)

39.6% (Over $470,701)

Married Filing Jointly and Surviving Spouses:

10% (Taxable income not over $19,050)

12% (Over $19,050 but not over $77,400)

22% (Over $77,400 but not over $165,000)

24% (Over $165,000 but not over $315,000)

32% (Over $315,000 but not over $400,000)

35% (Over $400,000 but not over $600,000)

37% (Over $600,000)

Married Filing Separately:

10% (Taxable income not over $9,325)

15% (Over $9,325 but not over $37,950)

25% (Over $37,950 but not over $76,550)

28% (Over $76,550 but not over $116,675)

33% (Over $116,675 but not over $208,350)

35% (Over $208,350 but not over $235,350)

39.6% (Over $235,350)

Married Filing Separately: 

10% (Taxable income not over $9,525)

12% (Over $9,525 but not over $38,700)

22% (Over $38,700 but not over $82,500)

24% (Over $82,500 but not over $157,500)

32% (Over $157,500 but not over $200,000)

35% (Over $200,000 but not over $300,000)

37% (Over $300,000)

Head of Household:

10% (Taxable income not over $13,350)

15% (Over $13,350 but not over $50,800)

25% (Over $50,800 but not over $131,200)

28%(Over $131,200 but not over $212,500)

33% (Over $212,500 but not over $416,700)

35% (Over $416,700 but not over $444,550)

39.6% (Over $444,550)

Head of Household:

10% (Taxable income not over $13,600)

12% (Over $13,600 but not over $51,800)

22% (Over $51,800 but not over $82,500)

24% (Over $82,500 but not over $157,000)

32% (Over $157,000 but not over $200,000)

35% (Over $200,000 but not over $500,000)

37% (Over $500,000)

Other Individuals:

10% (Taxable income not over $9,325)

15% (Over $9,325 but not over $37,950)

25% (Over $37,950 but not over $91,900)

28% (Over $91,900 but not over $191,650)

33% (Over $191,650 but not over $416,700)

35% (Over $416,700 but not over $418,400)

39.6% (Over $418,400)

Single Individuals:

10% (Taxable income not over $9,525)

12% (Over $9,525 but not over $38,700)

22% (Over $38,700 but not over $82,500)

24% (Over $82,500 but not over $157,500)

32% (Over $157,500 but not over $200,000)

35% (Over $200,000 but not over $500,000)

37% (Over $500,000)

Capital Gains Tax Rates

Tax Reform Bill
Married Filing Jointly (and Surviving Spouses):

15% Rate Threshold – $77,200

20% Rate Threshold – $479,000

Married Filing Separately:

15% Rate Threshold – $38,600

20% Rate Threshold – $239,500

Head of Household:

15% Rate Threshold – $51,700

20% Rate Threshold – $452,40

Other Individuals:

15% Rate Threshold – $38,600

20% Rate Threshold – $425,800

The above 15% and 20% threshold amounts will be indexed for inflation in tax years beginning after

2018.

The bill makes this provision effective for tax years beginning after 2017


Estate/ Gift Tax

  • Estate and Gift Taxes
    • Increases the federal estate and gift tax unified credit exclusion amount to $10 million (with inflation adjustments), effective for decedents dying and gifts made after December 31, 2017 and before January 1, 2026. No repeal of the estate tax.
  • Generation-Skipping Transfer Tax
    • Increases the federal GST exemption amount to $10 million (with inflation adjustments), effective for generation-skipping transfers made after December 31, 2017 and before January 1, 2026.  No repeal of the generation-skipping transfer tax.
2018 Estate and Gift Amounts for US individuals
Estate and Gift Tax Unified Credit Basic Exclusion Amount $10 million
Annual Gift Tax Exclusion $15,000 ($30,000 for joint gifts made by spouses)
GST Exemption $10 million

Charitable Contributions/ Non Profits

  • Charitable Contributions
    • For contributions made in years beginning after 2017 and before 2026, increases the AGI limitation on cash contributions from 50% to 60%, and repeals the current 80% deduction for contributions made for university athletic seating rights. Requires a contemporaneous written acknowledgement (i.e., a receipt) for contributions of less than $250, effective for contributions made in tax years beginning after December 31, 2016.  
  • Unrelated Business Taxable Income
    • Unrelated business taxable income will include any expenses paid or incurred by a tax exempt organization for qualified transportation fringe, a parking facility used in connection with qualified parking, or any on-premises athletic facility, provided such amounts are not otherwise deductible under section 274, for expenses paid or incurred after December 31, 2017.
  • Charitable Contribution Deduction for Electing Small Business Trusts (ESBT)
    • Beginning after December 31, 2017, the charitable deductions of an ESBT will no longer be determined by the rules generally applicable to trusts, individual rules apply. Therefore, the percentage limitations and carryforward provisions applicable to individuals will apply to charitable contributions made by the portion of an ESBT holding S corporation stock.
  • Excise Tax on Tax Exempt Organization Executive Compensation
    • For tax years beginning after 2017, imposes a 21% excise tax on compensation in excess of $1 million paid to an applicable tax-exempt organization’s five highest-paid employees in a tax year, and also applies a 21% excise tax to any parachute payment exceeding the portion of the base that is allocated to the payment (excluding employees who are not highly compensated).
  • Excise Tax on Investment Income of Private Colleges and Universities
    • Imposes a 1.4% excise tax net investment income of certain private colleges, universities, and related organizations that have at least 500 tuition paying students (50% of which are located in the US) which also has aggregate assets per-student of $500,000.

Other

Real Estate

  • Like-Kind Exchanges of Real Property
    • Only real property not primarily held for sale can have gain deferred in an exchange of like-kind property.
  • Mortgage Interest Deduction
    • Qualified residence interest is an allowable itemized deduction. However, in the case of taxable years beginning after December 31, 2017, and beginning before January 1, 2026, a taxpayer may treat no more than $750,000 as acquisition indebtedness ($375,000 in the case of married taxpayers filing separately). In the case of acquisition indebtedness incurred before December 15, 2017 this limitation is $1,000,000 ($500,000 if filing separately). For taxable years beginning after December 31, 2025, a taxpayer may treat up to $1,000,000 ($500,000 if filing separately) of indebtedness as acquisition indebtedness, regardless of when the indebtedness was incurred.
    • The deduction for mortgage interest deduction with respect to interest on home equity indebtedness for tax years beginning after December 31, 2017, and before January 1, 2026 is suspended.

Depreciation

  • Depreciation Limitation for Luxury Automobiles and Personal Use Property
    • Increases the depreciation limitations under §280F for passenger automobiles placed in service after December 31, 2017, to $10,000 for the year placed in service, $16,000 for the second year, $9,600 for the third year, and $5,760 for the fourth and later years.
  • Section 179 Expensing
    • Increases the amount that a taxpayer may expense under §179 to $1,000,000 and increases the phase out threshold to $2,500,000 (indexed for inflation for tax years beginning after 2018).
  • Depreciation Deductions for Nonresidential Real Property and Residential Rental Property
    • Maintains the present law general MACRS recovery periods of 39 and 27.5 years for nonresidential real and residential rental property, respectively. Defines a general 15-year MACRS recovery period for qualified improvement property.
  • Recovery Period for Farming Property
    • Effective for property placed in service after December 31, 2017, repeals the requirement that property used in a farming business use the 150% declining balance method.
  • Use of Alternative Depreciation System for Electing Farming Businesses
    • Requires a farming business electing to use ADS to depreciate property with a recovery period of 10 years or more, for tax years beginning after December 31, 2017.

For more information, please contact our Tax Law team at 941.748.0100 or by email:

Anthony Bartirome, LL.M., Taxation: abartirome@blalockwalters.com

Jenifer Schembri, CPA; Florida Board Certified in Tax Law; LL.M, Taxation: jschembri@blalockwalters.com

Kristen H. Ehrlich, LL.M., Taxation: kehrlich@blalockwalters.com