In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax penalties under Internal Revenue Code (Code)...more
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue Code (Code) Section 6038(b) against Alon...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
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
The Internal Revenue Service (IRS) ruled that a taxable real estate investment trust (REIT) subsidiary would not be considered to be operating or managing certain senior living and healthcare facilities located outside the...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
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Debt Financing ,
Economic Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investors ,
IRS ,
Low Income Housing ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tangible Property ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury