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Proposed Legislation Would Impose New Corporate Minimum and Excise Taxes

On Aug. 7, the Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the Act). If approved by the House of Representatives, as expected, the bill will be sent to President Joe Biden for signature. The bill passed by...more

New York State Budget Agreement Includes a Pass-Through Entity Tax as a SALT Workaround

On Wednesday, April 7, 2021, the New York Legislature reached an agreement with Governor Andrew Cuomo for the fiscal year 2021-2022 state budget. The agreed-upon budget package includes a number of revenue raisers ...more

Final Treasury Regulations Issued Addressing the Application of Section 1061 to Carried Interests

On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more

We Can Work It Out: Overcoming Obstacles to Real Estate Workouts

Real estate lenders and borrowers everywhere are trying to figure out what to do with properties that are either sitting vacant or underperforming pre-pandemic expectations. In New York, a number of mezzanine foreclosures...more

Real Estate Loan Purchases: Questions to Ask Before Finalizing a Deal

In an environment where real estate values are fluctuating and cash flows are difficult to predict, it is more important than ever to apply a comprehensive perspective when considering the purchase of real estate loans....more

Qualified Opportunity Fund Investments: Important Deadlines

The Qualified Opportunity Zone (QOZ) tax incentive program provides an opportunity for a taxpayer to defer and potentially eliminate the recognition of capital gains if, within certain 6-month time frames, the taxpayer makes...more

IRS Issues Additional Proposed Regulations on Qualified Opportunity Zones

On Dec. 22, 2017, the Qualified Opportunity Zone tax incentive program was signed into law as part of the Tax Cuts and Jobs Act of 2017....more

Important Changes To NYS Transfer and Mansion Taxes

As part of the 2020 budget, the New York State Senate and Assembly enacted new revenue legislation, which included an increase to New York State’s transfer tax and mansion tax on transfers of real property. ...more

A Qualified Opportunity Fund or a 1031 Exchange? Timing Is Key

The 2017 Tax Cuts and Jobs Act created new tax incentives for investing in the U.S. Among these is an opportunity to defer capital gains tax by reinvesting such gains in qualified opportunity funds (QOFs). ...more

South Dakota v. Wayfair and the End of Quill: Sales Tax Collection in a Digital Age

In a decision dated June 21 – South Dakota v. Wayfair – the Supreme Court held that no “physical presence” is required for a state to impose sales tax collection obligations on out-of-state vendors....more

Tax Reform

On Dec. 22, 2017, President Trump signed into law tax reform legislation (“the Act”) that will have wide-reaching impact across all sectors of the economy. This Client Alert summarizes the following changes to the Internal...more

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