In a surprising—but taxpayer-friendly—development, Treasury announced in Notice 2020-75 (available here) that it will be issuing proposed regulations that allow partnerships and S corporations to deduct certain state and...more
Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more
8/19/2020
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Popular ,
Private Equity ,
Proposed Regulation ,
Real Estate Investments ,
Tax Cuts and Jobs Act
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
8/14/2020
/ Business Taxes ,
Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
Proposed Regulation ,
Real Estate Investments ,
Reporting Requirements ,
Tax Cuts and Jobs Act ,
Tax Reform
The Coronavirus Aid, Relief, and Economic Security Act (H.R. 748; the CARES Act) includes several tax-related provisions, including tax rebates, modifications to the Tax Cuts and Jobs Act (TCJA), hiring and paid leave...more
The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more
1/15/2020
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Community Development ,
Economic Development ,
Final Rules ,
Grace Period ,
Incentives ,
Intangible Property ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Pass-Through Entities ,
Property Improvements ,
Property Valuation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Real Estate Transactions ,
Regulatory Requirements ,
Retail Installment Sales Contracts ,
Statutory Interpretation ,
Step-Up Basis ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
The IRS recently published Final Regulations and Notice 2019-12 largely blocking state efforts to circumvent limitations on deductions for state and local taxes. (See our alert on the Proposed Regulations, issued in August...more
6/27/2019
/ Business Taxes ,
IRS ,
Itemized Deductions ,
Liability Caps ,
Local Taxes ,
New Regulations ,
SALT ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform
OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM -
The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Corporate Entities ,
Investment Opportunities ,
Investment Property ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Reinvestment Funds ,
Rollover Equity ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax-Deferred Exchanges ,
U.S. Treasury
The IRS proposed regulations (the Proposed Regulations) on August 23, 2018, that would largely block state efforts to circumvent new limitations on income tax deductions for state and local taxes and would affect many current...more