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
The US Department of the Treasury and Internal Revenue Service (IRS) recently issued final regulations under section 1446(f), a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that generally imposes a...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