MEMORANDUM
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TO:
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Corporate
Attorneys
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FROM:
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Thomas
J. Mahoney, Jr.
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DATE:
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May
28, 2003
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RE:
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Federal
Tax Law Changes
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The
President signed into law today the "Jobs and Growth Tax Relief
Reconciliation Act of 2003" (the "Act") which reduces
tax rates and provides other incentives for business investment.
Of particular importance to our clients are the following provisions:
1. Reduction of Personal Income
Tax Rates. The Act accelerates
the previously passed reductions in marginal tax rates that were scheduled
to phase-in over the next three years. For 2003, tax rate brackets under prior law
and the Act are as follows:
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Prior
Law
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The
Act
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27%
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25%
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30%
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28%
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35%
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33%
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38.6%
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35%
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Since
many of our clients' businesses are S corporations or partnerships for
tax purposes, the individual rates are effectively the tax rates for
the business.
2. Increased Incentives for Business Investment.
a. Bonus Depreciation. Under
existing law, businesses placing new equipment in service before January
1, 2005 could take "bonus" depreciation of thirty percent
(30%) of the cost of the equipment in the first year of service. The Act increases the bonus depreciation to
50% of cost for equipment purchased and placed in service after May
5, 2003 and before January 1, 2005.
b. Expensing of Depreciable Business Assets. Presently a business can elect to expense (rather
than depreciate over time) up to $25,000 in business assets acquired
in a tax year. This benefit is
phased out dollar for dollar for businesses with purchases of over $200,000. The Act increases the amount that can be expensed
to $100,000 and increases the limit to begin the phase-out to $400,000.
3. Reduction of Capital Gain and Dividend Tax Rates. Presently, capital gains are taxed at a maximum
rate of twenty percent (20%) and dividends received by individuals are
taxed at the individual's marginal tax rate.
The Act reduces the maximum capital gains tax rate to fifteen
percent (15%) and taxes most dividends received by individuals at the
same rate as net capital gains, again with a maximum tax rate of fifteen
percent (15%).