Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/19/2021
/ Capital Gains ,
Claim Limitations ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Benefits ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
11/12/2021
/ Capital Gains ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors ,
Tax Deferral ,
Tax Liability ,
Tax Planning
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
10/21/2021
/ Business Entities ,
Business Property ,
Capital Gains ,
Eligibility Determination ,
Investment Funds ,
Investors ,
Opportunity Zones ,
Qualified Opportunity Funds ,
REIT ,
REMIC ,
S-Corporation
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more
10/21/2020
/ Allocation of Funds ,
Apportionment ,
CFC ,
Foreign Tax Credits ,
GILTI tax ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Research and Development ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On September 1, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations on the base erosion and anti-abuse tax (the BEAT) under section 59A. These regulations finalize...more
The CARES Act includes several key benefits for real estate stakeholders as they face the effects of the Coronavirus (COVID-19) pandemic. Many professionals should be able to receive immediate significant tax refunds...more
Covid-19 is creating unexpected tax exposure for foreign-based businesses with employees detained in the US and vice versa as companies may now find themselves with more sourced income than expected causing unforeseen tax...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
1/29/2020
/ Capital Gains ,
Community Development ,
Economic Development ,
Estate Planning ,
Final Rules ,
FIRPTA ,
Foreign Investment ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Partnerships ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Exempt Entities ,
Tax Planning ,
Trusts ,
U.S. Treasury
After nearly a decade of being put on hold, several members of the Senate Foreign Relations Committee have recently indicated that the first US-Chile Income Tax Treaty is expected to be approved by the end of the year. The...more
On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more
6/27/2019
/ 1603 Grants ,
Burden of Persuasion ,
Burden of Proof ,
Energy Sector ,
Evidence ,
Fees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Land Developers ,
Renewable Energy ,
Tax Credits ,
Wind Farm