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Tax Consequences of a Natural Disaster

Between wildfires such as the ones in Southern California earlier this year and hurricanes and other major storms experienced by other parts of the country annually, there is no shortage of natural disasters affecting people...more

Supreme Court Stays CTA Injunction in Texas Top Cop Shop Case, but CTA Reporting Still on Hold

In the Texas Top Cop Shop case, the U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued an injunction that deferred all reporting requirements under the Corporate Transparency Act (CTA). (See Holland...more

Final Regulations Issued on Penalty Supervisory Approval

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

IRS Notifies Thousands of Taxpayers After Personal Information Disclosed

The Internal Revenue Service (IRS) sent thousands of taxpayers a letter, alerting them of an unauthorized inspection or disclosure of their tax return or return information by a former IRS contractor, Charles Littlejohn....more

Developments in the Texas Top Cop Shop Case Impact Corporate Transparency Act

The U.S. District Court for the Eastern District of Texas on Dec. 3, 2024, issued a nationwide preliminary injunction suspending the government's enforcement of the Corporate Transparency Act (CTA) and its Implementing...more

IRS Issues Private Ruling That Entity with Zero Gross Income or Assets Can Qualify as a REIT

In private letter ruling (PLR) 202440007, the taxpayer (Taxpayer REIT) elected to be treated as a real estate investment trust (REIT) for its initial tax year. The Taxpayer REIT was formed as a vehicle to invest indirectly...more

Proposed Treasury Regulations Reverse Guidance on Domestically Controlled REITs

The U.S. Department of the Treasury and IRS on Dec. 29, 2022, published proposed regulations (Proposed Regulations) under Section 897 of the Internal Revenue Code of 1986, as amended (Code). The Proposed Regulations...more

Tax Considerations for Amending Commercial Leases Under Section 467 of the Code

The coronavirus (COVID-19) health crisis and associated economic downturn is expected to have a significant impact on commercial real estate lessees, as their ability to attract in-person customers and otherwise generate...more

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