On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
The federal Tax Cuts and Jobs Act of 2017 created a tax incentive program (the “Opportunity Zone Program”) that has the potential to provide a significant amount of funding for the development of renewable energy projects....more
Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program -
On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more
11/1/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
Low Income Housing ,
New Guidance ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On December 22, 2017, H.R. 1, the Tax Cuts and Jobs Act (the “Tax Act”) was signed into law. As the first comprehensive U.S. federal income tax reform in over thirty years, the Tax Act includes dramatic changes to tax...more
1/15/2018
/ Acquisitions ,
Alternative Minimum Tax ,
C-Corporation ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Net Operating Losses ,
New Legislation ,
Research and Development ,
Section 162(m) ,
Tax Cuts and Jobs Act ,
Tax Deductions
Last week, the long-awaited proposed bill for a comprehensive reform of the U.S. tax code (the “Proposed Tax Reform”) was finally released. While the Proposed Tax Reform is likely to be heavily negotiated further and possibly...more
11/9/2017
/ Capital Gains ,
Corporate Taxes ,
Estate Tax ,
Foreign Investment ,
Income Taxes ,
Investors ,
Joint Venture ,
Proposed Legislation ,
Real Estate Market ,
State and Local Government ,
Tax Deductions ,
Tax Reform ,
Ways and Means Committee
On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the...more
Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more