Spring 2026

Letter from the Chair

Dear Taxation Section Members:

It is my honor to serve as the Chair of the Section for the 2025-2026 fiscal year. I am looking forward to working with the Section’s Council and Committees to build upon the solid foundation laid by my predecessors. This year, members will see a continuation of our historically successful offerings, such as the Annual Tax Conference scheduled for May 21, 2026 in a new location, Troy, MI, Committee educational meetings, pro bono referral and grant programs and Tax Court Luncheons. 

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Section Committee Reports

Young Tax Lawyers - Kate Ahlbrand

Federal Income Tax - Bella Jordan

Employee Benefits - Katina Gorman

State and Local Tax - Scott Foess

Estates and Trusts - Joseph Haddad

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“Waiving” Farewell to 280G: Advising Privately Held Corporations Regarding Parachute Payments

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By Brandon P. Cross

It is not uncommon in the legal profession that the subject of employee benefits can get the “short shrift” within the context of corporation mergers or transactions. And this can be surprising, considering the potential size of the dollar amounts involved and what they often represent to recipients—financial security.

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Profits Interests: A Tax-efficient Way to Incentivize Employees

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By Christopher Attar

Offering equity in a business can be an effective strategy for attracting and retaining top talent.  It can also help incentivize employees to work toward growing the business.  For businesses taxed as partnerships, granting a profits interest is one of the most tax-efficient ways to provide equity.  Properly structured, a profits interest allows service providers to share in both the profits/losses of the business and any future appreciation in value of the business without an immediate tax to the recipient when the interest is granted.

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The Impact of OBBB’s Expansion of Section 1202 on Entity Choice

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By E. Murphy, Rebecca Pugliesi, and B. Jordan

In recent years, the dynamics of entity selection for businesses have shifted significantly. The federal tax rate for C corporations was permanently reduced from 35 percent to 21 percent in 2018, and the complexity associated with flow-through entities has continued to rise. As a result of these changes, an increasing number of businesses, including those backed by private equity, are opting for C corporation structures.

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Disclaimer

The opinions expressed herein are those of the authors exclusively and do not necessarily reflect those of the Editor, the Taxation Section Council, or the Taxation Section. It is the responsibility of the individual lawyer to determine if advice or comments in an article are appropriate or relevant in a given situation. The Editor, the Taxation Section Council, and the Taxation Section disclaim all liability resulting from statements and opinions contained in the Michigan Tax Lawyer.