On February 15, 2019, the Internal Revenue Service (the “IRS”) released PLR 201907001 (the “Ruling”), a private letter ruling addressing whether certain income related to the leasing of an oil and gas platform, selling of...more
5/3/2019
/ Capital Assets ,
Corporate Counsel ,
Equipment Lease ,
Internal Revenue Code (IRC) ,
IRS ,
Oil & Gas ,
Pipelines ,
Private Letter Rulings ,
REIT ,
Rental Income ,
Storage Tanks
On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more
4/22/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
REIT ,
Safe Harbors ,
Tax Deferral ,
U.S. Treasury
On September 13, 2018, the Internal Revenue Service (the “Service”) released Revenue Procedure 2018-48 (the “Revenue Procedure”), which provides guidance on how certain items of foreign-related income are treated for purposes...more
After months of being communicated through vague frameworks and political talking points, Republican tax reform proposals have finally been unveiled in legislative language. Earlier this month, H.R.1, the Tax Cuts and Jobs...more
On September 27, the Trump administration and the Republican leadership in the House and Senate released a document called the “Unified Framework for Fixing Our Broken Tax Code” (the “Framework”), which lays out the core...more
One of the headline proposals contained in the Republican Party’s “Better Way” blueprint for tax reform was immediate expensing of business investments. Although the Blueprint does not directly address like-kind exchanges,...more