Initially, tracking systems were employed to monitor the private jet usage of celebrities like Taylor Swift. Now, similar scrutiny will extend to executives who utilize business aircraft for personal purposes while claiming...more
On January 31, 2024, the United States House of Representatives passed the Tax Relief for American Families and Workers Act of 2024 (TRAFW Act), which is now under consideration in the Senate. The TRAFW Act, in addition to...more
In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more
As we move into the final quarter of 2022, it is critical to take note of an expiring tax benefit in the Tax Cuts and Jobs Act (TCJA). Passed in 2017, it allows for 100% bonus depreciation on a wide variety of capital assets...more
The Tax Court in Brief – February 28th-March 4th, 2022 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. ...more
On September 21, 2020, the IRS and Treasury Department released the last set of final regulations (the 2020 Final Regulations) under the bonus depreciation rules of Section 168(k) of the Internal Revenue Code (the Code). ...more
One of the key tax benefits for investors and owners of real estate such a senior living facilities is depreciation. The 2017 Tax Cuts and Jobs Act expanded on this benefit, allowing for 100% bonus depreciation for assets...more
The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more
Summary - Revenue Procedure 2020-25, issued on April 17, 2020, clarifies the process by which taxpayers are able to claim depreciation deductions including 100% “bonus depreciation” for the cost of certain leasehold and...more
The IRS issued Rev. Proc. 2020-25 providing much-anticipated guidance for how taxpayers may take advantage of the retroactive change in the tax rules allowing for expensing of Qualified Improvement Property (QIP)....more
If you’re reading this Legal Alert, then you may be one of the many business owners, real estate professionals, restauranteurs, or retailers who were disappointed at how the tax law changes enacted in the Tax Cuts and Jobs...more
On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more
Tax refunds are now available for certain improvements to nonresidential property (including office, restaurant, and retail improvements) that were placed in service in 2018 or 2019, even if the property is held by a...more
On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more
Economists maintain that income generated from an expensed capital asset is tax-free. We can’t verify that claim. We can confirm that expensing capital assets enhances investment returns. For this reason, bonus depreciation...more
On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more
The restaurant, retail and hospitality industries, among others, will be negatively affected by the qualified improvement property (QIP) drafting error in the Tax Cuts and Jobs Act (TCJA) (P.L. 115-97). This mistake will...more
The Internal Revenue Service (IRS) held a hearing on Nov. 28, 2018, regarding its proposed bonus depreciation regulations. Holland & Knight Partner John Hoover testified on behalf of the National Business Aviation Association...more
The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had temporarily expired. Following the...more
The Internal Revenue Service (IRS) has released a Notice regarding the tax treatment of meals, and the National Business Aviation Association (NBAA) has submitted comments to the IRS regarding the proposed regulations on...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus depreciation regime may work in the context of many common acquisitions involving...more