Last year’s Inflation Reduction Act created the Low-Income Communities Bonus Credit Program. This program provides additional energy tax credits on top of the existing 30% investment tax credit. According to Section 48(e) of...more
8/14/2023
/ Department of Energy (DOE) ,
Electricity ,
Energy Projects ,
Inflation Reduction Act (IRA) ,
Infrastructure ,
Internal Revenue Code (IRC) ,
Investment Tax Credits ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
Renewable Energy ,
Revenue Procedures ,
Tax Credits ,
Tribal Lands ,
U.S. Treasury
Monday, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued a press release and related notice regarding proposed regulations which clarify that the $10,000 cap on state and local tax (SALT)...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
In 2016, the Obama administration issued a series of rules and regulations designed to stem the flow of corporate inversions – transactions where U.S. corporations moved offshore to avoid the high 35% U.S. corporate tax rate....more
11/5/2019
/ Corporate Taxes ,
Deregulation ,
Financial Regulatory Reform ,
Foreign Corporations ,
Inversion ,
IRS ,
Regulatory Burden ,
Section 385 ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Trump Administration ,
U.S. Treasury
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. In early October, Treasury announced that it proposed to repeal or revise these regulations. ...more
As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more
As previously discussed, the IRS and Treasury identified in July eight Obama era tax regulations that are burdensome on taxpayers. The next step for Treasury was to determine what to do with these regulations, and today we...more
10/4/2017
/ C-Corporation ,
Debt-Equity ,
Deregulation ,
Foreign Corporations ,
IRC Section 2704 ,
IRC Section 367 ,
IRS ,
Regulatory Reform ,
REIT ,
RICs ,
Section 337 ,
Section 385 ,
Summons ,
Transfer of Assets ,
U.S. Treasury
As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts...more
Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more
7/18/2017
/ Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Foreign Corporations ,
Generation-Skipping Transfer ,
IRS ,
REIT ,
RICs ,
Section 103 ,
Section 337 ,
Section 385 ,
Tax Reform ,
Trump Administration ,
U.S. Treasury
Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more
7/12/2017
/ Corporate Taxes ,
Estate Tax ,
Executive Orders ,
Foreign Corporations ,
Gift Tax ,
GST ,
IRS ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Tax-Exempt Bonds ,
Transfer of Assets ,
Trump Administration ,
U.S. Treasury
As I previously discussed (here), President Trump issued an Executive Order requiring government agencies to identify two regulations for repeal for every new regulation that they wish to issue. The initial reaction of this...more
The Department of Treasury and IRS have finalized the regulations defining “real property” for purposes of the REIT rules. The regulations essentially adopt the proposed regulations...more
Yesterday, Senators Franken, Warren, Baldwin and Whitehouse sent Treasury Secretary Lew a letter regarding management fee waiver arrangements.
What is a management fee waiver arrangement? It is where a fund manager...more
Monday, the IRS and Treasury released proposed regulations governing the treatment of certain transfers of foreign goodwill and going concern value.
When a U.S. person contributes property to a foreign corporation,...more
In their continued effort to crackdown on offshore activity, the IRS and Treasury released proposed regulations yesterday that target debt held by foreign partnerships. These regulations provide that debt held by foreign...more
Wednesday, Senator Al Franken sent a letter to the Department of Treasury taking aim at “carried interest” income. In the letter, Senator Franken asked the IRS to revise Form 1065 (the tax return form for partnerships) to...more
In the 1990s, Treasury issued proposed regulations under Regulation Section 1.337(d)-3 commonly known as the “May Company” regulations. These proposed regulations dealt with situations in which a partnership owned stock of a...more
In what is becoming a popular refrain, we are continuing to hear tough talk by government officials on cracking down on offshore activity. The most recent target is once again corporate inversions. ...more