Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more
3/30/2020
/ Enforcement Actions ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
Installment Agreements ,
IRS ,
Offers in Compromise ,
Statute of Limitations ,
Tax Appeals ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Relief ,
Tax Returns
President Trump signed the Families First Coronavirus Response Act (the “Act”) on March 18, 2020. The Act becomes effective April 2, 2020, and contains a number of tax provisions that fund the Act’s mandatory paid leave...more
Yesterday, like other commentators, we reported that, in accordance with its terms, the Families First Coronavirus Response Act (“Act”) is effective on April 2, 2020. Please be aware, the U.S. Department of Labor (“DOL”)...more
I hope our readers, their families and co-workers are safe and remain healthy during these trying times. As a distraction for tax geeks like us from the news about the Coronavirus that is permeating our lives these days,...more
3/19/2020
/ Business Taxes ,
Commercial Activity Tax ,
Compensation ,
Corporate Taxes ,
Department of Revenue ,
Exclusions ,
Income Taxes ,
Independent Contractors ,
Rulemaking Process ,
State Taxes ,
Subcontractors ,
Tax Planning
Temporary Rules Keep Rolling in -
The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more
2/27/2020
/ Business Taxes ,
Car Dealerships ,
Commercial Activity Tax ,
Corporate Taxes ,
Documentation ,
Exclusions ,
Grocery Stores ,
Income Taxes ,
Motor Vehicles ,
New Guidance ,
Out-of-State Companies ,
Retailers ,
Safe Harbors ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Wholesale
A dog will immediately respond to you when you call out. On the other hand, when you call out to a cat, the cat will take a message and promise to get back to you later. This is not the case with the Corporate Activity Tax...more
Recent Announcements -
The Oregon Department of Revenue (the “Department”) has made several recent announcements regarding Oregon’s new Commercial Activity Tax (the “CAT”).
In an email dated December 4, 2019, the...more
12/20/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Income Taxes ,
New Rules ,
State Taxes ,
Substantial Nexus ,
Tax Liability ,
Tax Planning ,
Underpayment
In recent months, we have written extensively about Oregon’s new Corporate Activity Tax (the “CAT”). As discussed in our last post, the Oregon Department of Revenue (the “Department”) recently announced that it would hold a...more
We have written at length about Oregon’s new Corporate Activity Tax (the “CAT”). As discussed in our last post, the Oregon Department of Revenue (the “Department”) recently concluded a series of 12 town hall meetings around...more
We have been covering Oregon’s new Corporate Activity Tax (the “CAT”) over the past few months. As previously discussed, the Oregon Department of Revenue (the “Department”) has been conducting town hall meetings with...more
10/10/2019
/ Business Taxes ,
Corporate Taxes ,
Department of Revenue ,
Electronic Filing ,
Income Taxes ,
New Rules ,
Rulemaking Process ,
State Taxes ,
Tax Planning ,
Temporary Regulations ,
Town Hall Meetings
What We Learned from one of the Oregon Department of Revenue’s Town Hall Meetings -
Over the past few months, we have written extensively on the blog about Oregon’s new Corporate Activity Tax (the “CAT”). As announced in...more
10/3/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Exceptions ,
Grocery Stores ,
Income Taxes ,
Legislative Agendas ,
Registration Requirement ,
Regulatory Agenda ,
State Taxes ,
Tax Legislation ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Wholesale
We have recently discussed in several blog posts Oregon’s new Corporate Activity Tax (“CAT”), a gross receipts tax that will become effective January 1, 2020. As we announced in our most recent post on this topic, the Oregon...more
Earlier this year, rumors surfaced that the IRS plans to clean house and phase out all attorney positions from the Office of Professional Responsibility (“OPR”), an independent arm of the Service tasked with enforcing...more
As discussed in recent blog posts, the Oregon Legislative Assembly recently enacted a Corporate Activity Tax (“CAT”). Governor Kate Brown signed the legislation into law, effective January 1, 2020. Put in simplest terms, the...more
As we reported in our June 4 blog post, Oregon lawmakers had recently enacted a “corporate activity tax” (“CAT”) that applies to certain Oregon businesses. The new law, absent challenge, becomes effective January 1, 2020.
We...more
7/26/2019
/ Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Governor Brown ,
Income Taxes ,
New Legislation ,
Referendums ,
Repeal ,
State Taxes ,
Tax Legislation ,
Tax Planning
Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as...more
We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation.
On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more
6/5/2019
/ Business Ownership ,
Business Taxes ,
Commercial Activity Tax ,
Corporate Taxes ,
Department of Revenue ,
Goods or Services ,
Governor Brown ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Local Taxes ,
New Legislation ,
Popular ,
Referendums ,
Registration Requirement ,
Sales & Use Tax ,
State and Local Government ,
State Taxes ,
Substantial Nexus ,
Tax Legislation ,
Tax Planning ,
Tax Rates ,
Tax Returns ,
Tax Revenues ,
Underpayment ,
Unitary Business
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
4/24/2019
/ Anti-Abuse Rule ,
Asset Management ,
Capital Gains ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
Tax Benefits ,
U.S. Treasury
There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more
3/15/2019
/ Capital Gains ,
Deadlines ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Property Owners ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Sale of Assets ,
Tax Benefits ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
BACKGROUND -
Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
1/8/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Qualified Opportunity Funds ,
Real Estate Development ,
State and Local Government ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
U.S. Treasury
In Exelon, the Seventh Circuit held that exchanges by Exelon Corporation (“Taxpayer”) of nuclear power plants for long-term leasehold interests in power plants located in other states were not exchanges qualifying for...more
12/7/2018
/ Appraisal ,
Default ,
Deficiency Judgments ,
IRS ,
Leases ,
Power Plants ,
Public Utility ,
Real Estate Transfers ,
Repurchases ,
Section 1031 Exchange ,
Subleases ,
Tax Court ,
Third-Party