Business Organization Tax Residential Real Estate

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IRS Issues Another Significant Ruling on Spin-off of Real Estate

In certain recent transactions, a corporation distributes a subsidiary corporation holding the distributing corporation’s real estate assets to the distributing corporation’s shareholders in a tax-free “spin-off.” Not only...more

Proposed Section 752 Regulations and LIHTC Transactions: Part I

One of the hot topics at the recent ABA Taxation Section meetings in Washington, D.C. was the IRS’s proposed regulations regarding the allocation of partnership recourse and nonrecourse liabilities under section 752 of the...more

IRS Issues Long-Promised Guidance Following Historic Boardwalk Decision

To welcome in the new year, the Internal Revenue Service (the “IRS”) issued Rev. Proc. 2014-12, 2014-3 I.R.B. 415, to provide administrative guidance to the federal historic tax credit industry in the aftermath of the Third...more

Winthrop & Weinstine Summary of Revenue Procedure 2014-12

Scope of the Guidance & General Information - 1. Application of the Guidance is limited to allocations of HTC from Buildings that are placed in service on or after December 30, 2013. 2. This means the Guidance...more

RETT: Reentry of partner in property owning partnership

Transfer of interests leads to loss of qualification as a former partner within the meaning of Sec. 1 para 2a RETTA. The Federal Financial Court of Germany recently decided that real estate transfer tax (RETT) is due...more

BFH: Grunderwerbsteuer bei Wiedereintritt eines Gesellschafters in die Personengesellschaft

Verlust der (Alt-)Gesellschafterstellung in einer Personengesellschaft i.S.d. § 1 Abs. 2a GrEStG durch zivilrechtlich wirksame Übertragung des Mitgliedschaftsrechts. In einem kürzlich veröffentlichten Urteil (II R 3/11)...more

IRS Issues Important Historic Rehabilitation Tax Credit Guidance

Background - On December 30, 2013, the Internal Revenue Service issued its long-awaited historic rehabilitation tax credit guidance in the form of a Revenue Procedure that outlines a safe harbor for allocations of the...more

Michigan State Tax Commission Issues Clarification On New Uncapping Statute

As discussed previously on our blog, on December 14, 2012, the Michigan legislature enacted a law, Public Act 497 of 2012 (HR 4753), to prevent the uncapping of property taxes on certain transfers of residential property...more

Calif. Taxpayers: You Can['t] Check Out Any Time You Like

For California's high-earners and business owners, Proposition 30's passage in November 2012 was a "cross the Rubicon" moment. First, Proposition 30 increased tax rates retroactively to the beginning of 2012....more

Significant Pennsylvania Tax Changes

The General Assembly made significant changes to a number of Pennsylvania taxes as part of the 2013-2014 budget process. These changes were enacted in Act 52, signed into law on July 9, 2013, and have various effective dates....more

PA Tax Law News -- July 2013

In This Issue: PA Capital Stock/Franchise Tax Phase-Out Deferred; PA Board of Finance and Revenue Reconstituted as Independent Tax Tribunal; Annual PA Property Valuation Appeals Due Soon; Telecom Gross Receipts Tax...more

Maryland Expands Recordation and Transfer Tax Exemption to Include LLC Transactions

Effective July 1, 2013, Maryland’s recordation and transfer tax exemption for transfers of real property between related entities will be available to limited liability companies. The exemption, previously applicable only to...more

Tax Reform Update: Impact on Private Equity, Hedge Funds, and Real Estate Partnerships

Interesting tax update courtesy of Bruce Thompson, a Senior Policy Advisor with DLA Piper. He continues to see momentum for comprehensive tax reform and wrote the following summary of what that might mean for fund managers...more

Sweeping Maine Tax Reform Proposal Announced

A bipartisan group of 11 legislators have proposed an overhaul of Maine’s tax system, including major changes to the individual and corporate income tax, property tax, sales tax, and estate tax. ...more

Considerations For International Clients Who Intend to Buy A Home In the U.S.

International buyers invested $82.5 billion in U.S. residential real estate (4.8% of total U.S. sales) according to the most recent survey conducted by the National Association of Realtors for the 12 month period ending with...more

Third Circuit Court of Appeals Issues Landmark Decision in Virgin Islands Economic Development Program Case

Disclosure: Joseph A. DiRuzzo, III of Fuerst Ittleman David & Joseph was part of the trial team that represented the taxpayers in the June 2010 bench trial in the District Court of the Virgin Islands....more

Tax Kung Fu – Tax Structuring for Chinese Investment in U.S. Real Estate

Overview - Unless you have been traveling the galaxies for the last twenty years, you haven’t missed the “Chinese Miracle”. Its enormous impact is felt globally. When you see the skyline of Shanghai, the new meaning of...more

PA Tax Law News - February 2013

In This Issue: PA Governor Proposes Corporate Tax Cuts; Add-Back Legislation Reintroduced; PA Supreme Court Issues Business/Nonbusiness Income Decision; Philadelphia Property Reassessments; Commonwealth Court Addresses...more

MoFo New York Tax Insights - Volume 4, Issue 2 - February 2013

In This Issue: Divided Appellate Division Affirms Tribunal’s Gaied “Permanent Place of Abode” Decision; Combined Reporting Permitted by ALJ Despite Absence of Substantial Intercorporate Transactions; Commissions Paid...more

UK property tax changes: “de-enveloping” or a use of a trust?

It has long been popular for high net-worth people who are not domiciled in the United Kingdom (“non-doms”) to form an offshore company, often in the British Virgin Islands (“BVI”), for the purposes of holding property in the...more

"Penn National Gaming, Inc. Announces First-Ever Tax-Free PropCo REIT Spin"

Penn National Gaming, Inc. (PNG) announced last evening the first-ever tax-free spin-off of a “PropCo” real estate investment trust (REIT) from a taxable C corporation. PNG intends to separate its real property gaming...more

MoFo New York Tax Insights - Volume 3, Issue 11 - November 2012

In This Issue: Appellate Court Holds “Reconstitution” of Housing Cooperative Is Not Subject to City Transfer Tax; Trial Court Upholds Retroactive Application of 2010 Statutory Amendment; Tribunal Holds S Corporation...more

Acquisition and Rehabilitation Opportunities: Projects with an Expiring Nine Percent Tax Credit Compliance Period

Residential rental projects financed with “9%” low income housing tax credits in the late 1990’s or early 2000’s offer, or will soon offer, special opportunities for acquisition/rehabilitation financing with tax exempt bonds...more

Proposition 218’s Ban On Tax Increases Without Voter Approval Does Not Apply To Annexations

In Citizens Association of Sunset Beach v. Orange County Local Agency Formation Commission (--- Cal.Rptr.3d ----, Cal.App. 4 Dist., October 5, 2012), a California Court of Appeal considered whether Proposition 218’s ban on...more

Upscale Retirement Complex Denied Religious and Charitable Property Tax Exemptions

The Second District Appellate Court recently upheld the Department of Revenue’s denial of a property tax exemption for the Village at Victory Lakes in Lindenhurst, Illinois, which is a continuing care retirement community...more

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