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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

IRS Issues Additional Guidance on REIT Parking Facility Income

In the recently released Private Letter Ruling 201628020, the IRS considered a situation where affiliated entities owned various properties in an office park; the IRS determined that the entities’ income from leasing space in...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

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

Development of practice on treating of facilities as immovable property for the purpose of imposing corporate property tax

On 12 July 2016 the Commercial Court of Moscow rendered a decision in case No. ?40-98958/16-108-827. This case considered a dispute between ORSKNEFTEORGSINTEZ OJSC (the “Company”) and Federal Tax Service Interregional...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

IRS Releases Temporary and Proposed Regulations Under IRC Section 50(d)(5)

On July 21, 2016, the IRS released temporary regulations section 1.50-1T under IRC Section 50(d)(5) of the Internal Revenue Code (the "Temporary Regulations") (TD 9776) that provide guidance regarding: (1) the income...more

New Hampshire Enacts Business-Friendly Tax Changes

Three business-friendly tax bills have become law in New Hampshire. Each bill will result in tax reductions for those able to take advantage of them. The New Hampshire Business Profits Tax generally “piggybacks” on the...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

Treasury Department Issues New REIT Spinoff Rules

The Treasury Department today released new temporary and proposed regulations that will impact spinoffs and REIT conversions and modify the definition of “converted property” with respect to REIT transactions....more

South Carolina Textiles Communities Revitalization Act Enhanced

On May 23, 2016 the South Carolina Textiles Communities Revitalization Act was amended to remove a fifty percent cap applicable to the income tax credit provided by the Act. L. 2016, H5009. This taxpayer-friendly amendment...more

Third Circuit Holds SCRA Protections Do Not Extend to Servicemember-Owned Businesses

In a unanimous opinion in Davis v. City of Philadelphia, the U.S. Court of Appeals for the Third Circuit has held that Servicemembers Civil Relief Act (SCRA) protections do not extend to a servicemember's solely owned...more

Pennsylvania Property Tax Reassessment Update

Several counties in Pennsylvania are conducting countywide property reassessments. This update provides status changes for Washington, Blair and Lancaster Counties, along with a set of important deadlines and basic assessment...more

Here’s the Deal: Georgia Governor Signs Several Significant Tax Bills

Following the conclusion of Georgia’s 2016 legislative session, Governor Nathan Deal signed into law several tax bills touching on a wide range of tax matters, including sales and use taxes, property taxes, corporate income...more

Key Economic Incentives for Businesses Considering a Florida Location

The State of Florida offers economic incentives to businesses that are thinking about locating—or relocating—in Florida. These incentives target corporate headquarters and certain high growth industries. In addition, many...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

Lease Receipts Subject to Business Privilege Taxes After All

The Pennsylvania Supreme Court recently reversed a 2014 Commonwealth Court decision in which the Commonwealth Court had ruled that the Local Tax Enabling Act (“LTEA”) bars local taxing jurisdictions from imposing business...more

Tax and Non-Tax Reasons to be Cautious about “Bad Boy Nonrecourse Carve-out Guarantees” - IRS Backtracks on Recent Conclusion that...

On April 15, 2016 the IRS reversed its controversial position that bad boy guarantees may convert nonrecourse debt into recourse debt. General Legal Advice Memorandum Number AM2016-001 released April 15, 2016 effectively...more

[Event] Spring 2016 Tax Forum - May 12th, 8:00 am, Richmond, VA

Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 12, 2016. Topics Include: Contributions of Property to a Partnership: An Analysis of Section 704(c) Methods Part II:...more

IRS Agrees Traditional Bad Boy Guarantees Do Not Change Character of Nonrecourse Loan

The Internal Revenue Service has apparently seen the light — at least with respect to the effect of “bad boy” guarantees on a loan that is otherwise nonrecourse for income tax purposes. Last month, we reported that the IRS...more

Closing California’s Perceived Prop 13 Corporate Loophole

SB 259, a bill that includes language to close the perceived loophole in the portion of Proposition 13 which governs “changes of ownership” in entities that own real property located in California, has been returned to the...more

CHINA EXPANDS VAT REFORM TO NEW SECTORS

China's Premier Li Keqiang has announced, in the Annual Government Working Report to the National People's Congress, held in March that Value Added Tax ("VAT") reforms will be fully implemented and expanded from 1 May 2016 to...more

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