It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more
In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more
“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more
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
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
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
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
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
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
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
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
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
BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
The Treasury Department and Internal Revenue Service issued proposed regulations and other guidance on the new "opportunity zone" tax incentive on October 19, 2018. This tax incentive encourages investment in certain...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
There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more
New Campaigns Announced - On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new campaigns continue the IRS’s move to...more
An IRS tax levy is a seizure of a person’s property or rights to property. The IRS then uses the seized property to pay taxes owed. A levy allows the IRS to confiscate a person’s property, which includes cars, boats, real...more
In early November, I posted an article entitled “Tax Reform Proposal Nixes Favorable Tax Treatment of Several Employee Benefits”. That article reviewed the Ways and Means Committee’s proposal (H.R. 1, the Tax Reform and Jobs...more
On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations...more
On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would...more
While not purporting to give specific advice on Nevada tax law, the following is a summary of some of the general principals underlying the new tax law. A new Nevada Commerce Tax (“NCT”) was signed into law by Nevada Governor...more
In new Rev. Proc. 2015-20, the IRS permits a “small business taxpayer” to use a simplified procedure to change its method of accounting under the final tangible property regulations for tax years beginning on or after January...more
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
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