Commercial Real Estate General Business Tax

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New North Carolina Sales Tax Provisions for Contracts Related to Real Property

This alert is relevant for contractors who perform construction services on real property in the state of North Carolina. In South Carolina, contractors remain subject to the traditional sales or use tax at the time of all...more

Ratings – the road to revaluation

On 1 April 2017 the business rates revaluation will take effect. This in itself is cause for significant concern. However, the ratings world is currently a maelstrom of upheaval and controversy, such that the revaluation is...more

IRS Issues Final Regulations on REIT and RIC Conversion Transactions

The U.S. Treasury Department and the Internal Revenue Service published on January 18, 2017 final regulations (the “Final Regulations”) reducing from ten years to five years the recognition period for the corporate-level tax...more

Michigan Tax News - January 2017

Michigan’s 2017 property tax assessment notices are in the mail. Should you appeal? Local assessors are in the process of sending annual notices of real and personal property tax assessments to property owners/taxpayers,...more

Recent Developments in Partnerships and Real Estate 2017

The IRS released a flurry of new rules as the Obama administration came to a close. The attached presentation provides an overview of many of these developments in the partnership and real estate tax area, including a...more

Management Contracts Safe Harbors Revisited – IRS Releases Updated Guidance (Again)

Demonstrating the “user-friendly” side of the IRS, on January 17, 2017, the IRS released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”) (available here) to address many (but not all) of the comments received on the rather...more

South Carolina Department of Revenue Issues Property Tax Guidance for Fiscal Year Manufacturers

The South Carolina Department of Revenue (the “Department” or “DOR”) issued SC Revenue Ruling #16-12 on December 16, 2016. The ruling provides guidance to manufacturers on property tax return filings, assessment procedures,...more

Amendments to Philadelphia's Realty Transfer Tax Will Have a Significant Impact

Recent amendments to Philadelphia’s realty transfer tax will likely change the way commercial real estate is bought and sold. Rather than sell the real estate directly and record a traditional deed to evidence the...more

South Carolina Economic Development Incentives for Warehouse and Distribution Operations

South Carolina offers a wide variety of economic development incentives to businesses seeking to locate or expand in the state. This incentive array focuses on certain types of businesses the state wishes to attract. One such...more

New Regulations Issued Regarding CFCs and Investment in U.S. Property

Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on...more

Beware a Prop W Higher Transfer Tax

Transfer tax on the sale of most commercial property in San Francisco will increase if voters approve Proposition W. If approved, Prop W will increase the transfer tax rate by 0.25% for sales valued above $5 million...more

Private Ruling Exempts Property Management Services from Self-Dealing

A new private ruling may be of great interest to clients with substantial real estate interests who wish to contribute one or more properties to a family foundation. The ruling suggests that payment by the foundation to a...more

Recent Developments for Indonesian REITs

On 17 October 2016, President Joko Widodo signed Government Regulation No. 40 of 2016New Tax Incentives for Indonesian REITs"). 1 ("GR 40"). GR 40 changes the tax rate imposed on the transfer of property (land and building)...more

Construction Industry Scheme - taxing our landlords and tenants

The Construction Industry Scheme (‘CIS’) requires contractors to withhold tax from payments to subcontractors in relation to certain construction work. It is easy to assume that CIS only applies to mainstream contractors, but...more

There is life after death...of the Bottom-Dollar Guarantee

Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more

MoFo Tax Talk - Volume 9, No. 3

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

New Regulations Dramatically Alter Partnership 'Disguised Sales' and Allocation of Partnership Liabilities

On October 4, 2016, the Internal Revenue Service and the Treasury Department issued a sweeping package of proposed, temporary and final regulations under the Internal Revenue Code that, among other things, significantly...more

Final Regulations Define “Real Property” for REITs: Considerations for Renewable Energy and Transmission Assets

The recently released final regulations are generally consistent with the 2014 proposed regulations in their treatment of renewable energy and transmission assets, with several useful clarifications provided. ...more

Changes to PA Business Corp. Law may affect the way Commercial Real Estate is owned in PA

For decades owners of commercial real estate in Pennsylvania took title in limited partnerships, not necessarily because it was the best entity to own and manage property, but because it minimized the effect of the Capital...more

Regulations Finalized on REIT Real Property Rules

The Department of Treasury and IRS have finalized the regulations defining “real property” for purposes of the REIT rules. The regulations essentially adopt the proposed regulations...more

IRS Publishes New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds

On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more

Client Alert: New Safe Harbors for Management Contracts of Tax-Exempt Financed Facilities

The Internal Revenue Service on August 22, 2016 released Revenue Procedure 2016-44 which revises the safe harbor guidelines for management contracts of service providers for tax-exempt financed facilities, under which the...more

South Carolina Property Tax Incentives: The Special Source Revenue Credit

While South Carolina has low income taxes, and comparatively low sales taxes as well, the state makes up for this by having some of the highest business property tax rates in the Southeast. These property taxes are generally...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

South Carolina Department of Revenue Audits

The South Carolina Department of Revenue (SCDOR) administers the state’s tax laws. Like the IRS, SCDOR audits tax returns, but only certain returns subject to South Carolina tax, such as South Carolina income tax returns,...more

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