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Safe Harbors Tangible Property

Pillsbury Winthrop Shaw Pittman LLP

Technology Transfer Agreements: Latest Developments in California

Since their introduction in California in 1993, the sales and use taxation of technology transfer agreements has been the subject of significant litigation and a seemingly endless regulation project. In the past few...more

McGlinchey Stafford

Winners And Losers In Like-Kind Exchange Final Regulations

McGlinchey Stafford on

The Treasury Department and the IRS received 21 written comments in response to the like-kind exchange proposed regulations (see our earlier alert). The recently issued final IRS like-kind exchange regulations adopt some...more

Tonkon Torp LLP

IRS Proposes New 1031 Regulations – Sculptures Are Real Property, Walls Are Not

Tonkon Torp LLP on

The IRS issued Proposed Regulation 117589-18 on June 11, 2020 (the “Proposed Regs”), in response to legislative changes applicable to like-kind exchange transactions (“1031s”). The Proposed Regs address transactions involving...more

Harris Beach PLLC

Treasury Releases Second Round of Proposed Opportunity Zones Regulations

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On April 17, 2019, the Treasury released long-awaited additional regulations and guidance with respect to Section 1400Z-2 of the Internal Revenue Code, concerning the Qualified Opportunity Zones (“QOZs”) Program (the...more

Burr & Forman

Recent Opportunity Zone Regulations Benefit Entrepreneurs

Burr & Forman on

Congress enacted the Opportunity Zone (“OZ”) investment incentives in late 2017 as part of the Tax Cuts and Jobs Act. Since then many investors, fund managers, and community development professionals have devoted significant...more

Akin Gump Strauss Hauer & Feld LLP

Latest Opportunity Zone Rules Clarify Issues Related to Fund Structuring, Qualifying Businesses and Business Property

• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Sullivan & Worcester

Second Round of Treasury Guidance: Key Provisions

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The long-awaited second round of Opportunity Zone-related Proposed Regulations were issued Wednesday, April 17, 2019. It is clear that Treasury’s goals, in its second round of guidance, were to: 1. Provide clarity and/or...more

Katten Muchin Rosenman LLP

Additional Proposed Regulations Issued Regarding Opportunity Zones

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Stoel Rives LLP

Treasury Issues New Proposed Qualified Opportunity Zone Regulations

Stoel Rives LLP on

The Department of the Treasury on April 17 released a highly anticipated second round of proposed regulations regarding investments in qualified opportunity zones. The opportunity zone incentive was enacted as part of the Tax...more

PilieroMazza PLLC

What Every Business Owner Needs to Know About Implementing the New Tangible Property Regulations

PilieroMazza PLLC on

Over the last several years, the IRS has published a series of regulations and rulings that dramatically change how taxpayers must account for the costs of acquiring, repairing, improving and even disposing of tangible...more

Troutman Pepper

Complying With The Tangible Property Regulations – Procedural Guidance Provides Favorable Rules That Require Immediate...

Troutman Pepper on

Late last year, the IRS and Treasury Department released final and proposed regulations that affect the tax treatment of costs associated with plants, buildings, equipment, and machinery. These rules affect the costs...more

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