Business Organization Residential Real Estate Tax

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New Filing Guidance for PTEs Participating in Rehabilitation Credit Projects

In CCA 201641022 (October 7, 2016) (the “CCA”), the IRS issued new guidance regarding filing requirements for pass-through entities (“PTEs”) involved in rehabilitation credit projects. Under this new guidance, (1) a PTE may...more

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. ?11-6602/2016 (the “Decision”) under the claim of Vladimir Energy RetailCompany1 Public Joint-Stock Company (the “Company”)....more

The Basics of 1031 Exchanges – Part Two: Structuring Partnership/LLC 1031 Exchange Cash-out Transactions

This is part two of a two-part series on Internal Revenue Code Section 1031 tax-deferred exchange transactions. The first article provided an overview of the basic rules that govern 1031 exchanges. This article describes...more

Did San Francisco Eliminate its Transfer Tax Exception for Certain Gifts?

It seems that San Francisco may have just partially removed its exception from transfer tax that applied to gifts, but the Office of the Assessor-Recorder may not be aware. As a bit of background, transfer tax applies to...more

The Basics of 1031 Exchanges - Part One

This is part one of a two-part series on Internal Revenue Code Section 1031 Tax-Deferred property exchanges. This first article will provide an overview of the rules that govern 1031 exchanges. Part two will deal with the...more

Michigan Governor Signs Law Excluding Library Taxes from Capture by Tax Increment Financing Entities

On Jan. 9, 2017, Michigan Governor Snyder signed into law a package of bills, all with immediate effect, that would exempt certain taxes levied for library purposes from being captured by tax increment financing authorities,...more

IRS Rules That Syndicated Conservation Easements With Inflated Appraisals Are Listed Transactions

In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more

Disposing of Real Property in a Tax-Advantaged Manner

Many of our clients are heavily invested in real property. In some cases, this investment may be a single property in a prime location; in others, the client (and maybe his family) is in the business of owning and operating a...more

Reaction to Uncertainty in Affordable Housing Industry Brought on by Trump Election

The 2016 Election has created more questions than answers for the affordable housing industry. Very little is known about President-elect Trump's vision for affordable housing. On one hand, Mr. Trump has described himself as...more

UK Autumn Statement 2016: inheritance tax and business property relief | Insights | DLA Piper Global Law Firm

In the 2016 Autumn Statement, The Chancellor announced that reforms, originally proposed in Summer Budget 2015, to inheritance tax and business investment relief for non-UK domiciled individuals will come into effect from 6...more

Luxembourg Real Estate - Tax and Legal Developments

This brief report provides a summary of the most recent Luxembourg tax developments that currently affect and will be affecting real estate practitioners throughout 2017....more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

Using corporate structures to own UK residential property – a dead end?

Historically, UK resident non-domiciled individuals have been able to achieve certain tax advantages through holding interests in UK residential property through offshore companies. In recent years, the UK government has...more

MoFo New York Tax Insights - Volume 7, Issue 10

Recent unpublished NYC Department of Finance Letter Rulings - We have obtained under the Freedom of Information Law several Finance Letter Rulings of interest, most involving the New York City real property transfer tax,...more

Final IRS Regulations Clarify That Certain Solar Assets May Qualify as Real Property for REIT Purposes

On August 30, 2016, the IRS issued final regulations that clarify and expand the definition of "real property" for purposes of qualifying as a real estate investment trust (REIT). The final regulations substantially follow...more

Use of Shell Companies To Shield Identity Further Limited

On July 27, 2016 the Financial Crimes Enforcement Network, (FinCEN) of the Department of the Treasury issued expanded Geographic Targeting Orders (GTO) that will...more

Major Tax Legislation Enacted by the Short Session of the 2015-16 General Assembly

This Alert summarizes the major tax provisions included in legislation passed by the 2015-2016 North Carolina General Assembly in its short session, which concluded earlier this month. The most widely discussed tax...more

Remission of stamp duty on certain conveyance directions - Licensed housing developers

Introduction - 1. Where a party (Vendor) enters into an agreement (Main Contract) to transfer any immovable property (Property) to another party (Initial Purchaser), and before having obtained a conveyance of the...more

Net Operating Loss Cap is Unconstitutional

In RB Alden Corp. v. Commonwealth, No. 73 F.R. 2011 (Pa. Commw. June 15, 2016), the court addressed the taxpayer’s liability for 2006 Corporate Net Income (CNI) Tax on gain from the sale of part of its interest in a...more

Treasury Expands Scope of REIT Spin-Off Rules in New Regulations

On June 7, the Treasury Department released temporary regulations (the “Temporary Regulations”) that expand the types of spinoff transactions subject to the rules under Section 337(d)2 requiring gain recognition where either...more

My “Flippín” House?

Tax Strategies to Reduce Taxation and Build Wealth for House Flippers - Overview - I seem to be perpetually out to lunch. When I step on the scale too, this point is further confirmed. I do not know why I have...more

IRS Issues Temporary and Proposed Regulations Focused on REIT/RIC Conversion Transactions

The regulations affect both real estate investment trusts (REITs) and regulated investment companies (RICs) that receive appreciated property from a C corporation in a so-called “conversion transaction.”...more

Waivers of Ownership Limitation Provisions in REIT Charters

I. Why Do REITs Have Ownership Limits in the First Place? - Ownership limitation provisions are designed primarily to protect one of a REIT’s most valuable assets – its status as a REIT under the federal income tax...more

"IRS Expands REIT Spin-Off Restrictions, Extends REIT Built-in Gains Period to 10 Years"

On June 7, 2016, the Internal Revenue Service (IRS) and Treasury Department issued new temporary regulations that have dramatic implications for all merger-and-acquisition activity by C corporations and real estate investment...more

Update: New IRS Memo on Bad Boy Guarantees

Prior Alert. The March 17 Alert noted that the IRS in a Chief Counsel Advice ("CCA") had discussed the effect that certain “bad boy carve-out guarantees” (that would trigger contingent guarantee obligations if, for example,...more

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