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The Nonqualified Financial Property Limitation

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

The 90 Percent Test

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

GILTI High-Tax Exclusion: An Additional Planning Tool for Noncorporate US Shareholders

An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more

Treasury Provides Additional Guidance on Opportunity Zone Provisions

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

Guidance in Proposed Regulations Expected to Jumpstart the Benefits of Qualified Opportunity Zone Investing

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions as an incentive for taxpayer investment in low-income neighborhoods and combined the benefits of both tax deferral and tax elimination. On October 19,...more

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