News & Analysis as of

Capital Gains Installment Agreements

Levenfeld Pearlstein, LLC

A Tale of Two DSTs: Beware of Confusing 1031 DSTs with 453 DSTs

Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

Rivkin Radler LLP on

I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Rivkin Radler LLP

“Earth To Earth”: Real Estate, Death And Biden’s Tax Proposals

Rivkin Radler LLP on

Go After Real Estate? During the 2020 presidential campaign, there was one segment of the “rich” for which then-candidate Biden seemed to have reserved some of his harshest criticism – wealthy real estate investors....more

Ervin Cohen & Jessup LLP

Locking in 2012’s Long-Term Capital Gains Tax Rate

Did you sell your business in 2012 and defer any of the purchase price? This could be the case if you financed part of the purchase price (i.e., you took back the buyer’s note), or there was an earnout whereby you receive...more

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