This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
On 7 October 2020, the Treasury Department and the Internal Revenue Service (IRS) released final regulations under Code Section 1446(f) (the Final Regulations), which clarify aspects of the withholding requirements with...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
Prior to 2017 Tax Cuts and Jobs Act (TCJA), private equity fund, hedge fund, and other investment fund or asset managers that received an interest in an entity taxed as a partnership for U.S. federal income tax purposes (a...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
On 28 August 2020, the IRS issued eagerly awaited guidance on the implementation of the employee FICA payroll deferral authorized in a Presidential Memorandum (the Memorandum) signed by President Trump on 8 August 2020....more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
This guide outlines the tax provisions contained in the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), and certain related notices issued by the...more
After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more
5/6/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
In December 2017, Congress enacted The Tax Cuts and Jobs Act (the “Tax Cuts Act”). Included in that tax legislation is what has come to be called the opportunity zone incentive (“OZ Incentive”): a host of dramatic new tax...more
Treasury decisions could make or break OZ for operating businesses -
Eagerly anticipated proposed regulations addressing the eligibility of operating businesses to qualify for Opportunity Zone (OZ) benefits are in the final...more
3/26/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investors ,
IRS ,
Opportunity Zones ,
Popular ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments
The Tax Cuts and Jobs Act (the “Act”) created a significant new tax incentive for taxpayers that invest capital gains in Qualified Opportunity Funds (each a “QOF” and collectively, “QOFs”). Investors can defer paying tax on...more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral
The Internal Revenue Service (“IRS”) has released proposed regulations explaining how taxpayers should calculate the Section 199A deduction for qualified business income. ...more
The tax reform bill signed into law by President Trump on December 22, 2017, taxes U.S. shareholders on their share of the previously untaxed deferred income of foreign corporations. Known as “deemed repatriation,” this tax...more
In a recently published decision, the U.S. Tax Court declined to follow the longstanding position of the U.S. Internal Revenue Service (“IRS”), articulated in Revenue Ruling 91-32, that a non-U.S. partner’s gain or loss from...more
On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”). Among its numerous revisions to federal tax law, the PATH Act significantly amended various...more
On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more