News & Analysis as of

Tax Business Organization Residential Real Estate

Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Emmanuel Macron Elected President: French Taxation to Fall in Line with the European Average?

by Dechert LLP on

Following the election of Emmanuel Macron as President of the French Republic, you will find below a few examples of expected tax changes of potential importance to our clients....more

Have Yourself a Very Trumpy Tax Plan

by Dechert LLP on

Well, we’ve had the big reveal and the administration’s new tax plan is out. This plan, announced with a great deal of fanfare, feels more like a campaign promise than an actual executable plan. At two hundred forty-six...more

IRS Announces Disagreement with Ninth Circuit’s Holding on Completed Contract Method of Accounting

by Miles & Stockbridge P.C. on

The IRS recently announced its disagreement with the Ninth Circuit’s ruling that, with respect to planned communities, the 95% test under the completed contract method of accounting applies on a development-wide basis rather...more

A Guide to UK Tax on Commercial Real Estate: Non-Residents

by King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

New stamp duties on shares transfer – Acquisition and disposal of equity interests in residential property holding entities

by Dentons on

Purchases of residential properties in Singapore by companies attract Additional Buyer Stamp Duty (ABSD) of 15% rate in addition to usual Buyer Stamp Duty (BSD) of up to 3%. Seller Stamp Duty (SSD) is also payable if...more

Properly structured foreign gifts of real property property can be estate and gift tax free

by Sanford Millar on

The investment in U.S. real property by Non-residents can be structured to minimize estate and gift taxes. The key is to structure the investment through a limited liability company, limited partnership or corporation so...more

Stay out of TROUBLE: Make sure your CPA is asking you the right QUESTIONS regarding Foreign Accounts!

by Foodman CPAs & Advisors on

US International tax is complicated. It often overwhelms US Taxpayers. That is why an international tax specialist CPA is the best choice for the work. Nonetheless, many Taxpayers seek the help of tax return preparers...more

When A “Tax Free” Exchange May Not Be Free of Tax

by Farrell Fritz, P.C. on

“Tax free” – two words that often bring great delight when they are spoken by a tax adviser to the owner of a business, whether he is considering the disposition of a single asset, or of substantially all of the assets, of...more

New Filing Guidance for PTEs Participating in Rehabilitation Credit Projects

by Miles & Stockbridge P.C. on

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

by Dentons on

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

by Ward and Smith, P.A. on

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

by Ward and Smith, P.A. on

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

by Miller Canfield on

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

by McNair Law Firm, P.A. on

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

by Farrell Fritz, P.C. on

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

by DLA Piper on

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

by Dentons on

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?

by Dechert LLP on

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

by Morrison & Foerster LLP on

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

by Sanford Millar on

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

by Smith Anderson on

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

119 Results
|
View per page
Page: of 5
Cybersecurity

Follow Tax Updates on:

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.