Broadly syndicated Section 1031 investment programs, such as DSTs and TICs, have been popular with a growing number of real estate investors since the early 2000s due to their ability to allow investors to reinvest in...more
Seyfarth Synopsis: On April 12, 2021, the Department of Treasury (“Treasury”) published proposed Treasury regulations (the “Proposed Regulations”) that (1) permit qualified opportunity zone businesses (“QOZBs”) to revise or...more
Seyfarth Synopsis: On January 19, 2021, the Internal Revenue Service (the “IRS”) issued Notice 2021-10 (the “Notice”), which extends the relief that it previously provided to qualified opportunity funds, their sponsors, and...more
Seyfarth Synopsis: On January 19, 2021, the Internal Revenue Service (“IRS”) issued guidance (the “Guidance”) in accordance with the recently enacted COVID-related Tax Relief Act of 2020 (the “Act”) extending the payment...more
Seyfarth Synopsis: On August 28, 2020, the Internal Revenue Service (“IRS”) issued guidance (the “Guidance”) to implement the payroll tax withholding and payment deferral provided for in President Trump’s Presidential...more
Seyfarth Synopsis: On August 8, 2020, President Trump issued an Executive Order and three Memoranda to his Cabinet and Executive Agency heads (collectively, the “Executive Orders”) that provide or extend COVID-19 relief to...more
8/11/2020
/ Coronavirus/COVID-19 ,
Eviction ,
Executive Orders ,
Infectious Diseases ,
Moratorium ,
Payroll Taxes ,
Relief Measures ,
Social Security ,
Student Loans ,
Tax Deferral ,
Trump Administration ,
Unemployment Benefits
Seyfarth Synopsis: On June 12, 2020, the US Department of Treasury (the “Treasury”) promulgated proposed treasury regulations (the “Proposed Regulations”) under section 1031 (“Section 1031”) of the Internal Revenue Code of...more
In Notice 2020-39, issued on Thursday, June 4, 2020, the IRS made substantial accommodations to Qualified Opportunity Funds, and their sponsors and investors, to allow them to address the challenges presented by COVID-19....more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
4/14/2020
/ Accounting ,
Alternative Minimum Tax ,
Business Assets ,
Business Income ,
Business Taxes ,
C-Corporation ,
Capital Gains ,
Capital Losses ,
Corporate Taxes ,
Cost Recovery ,
Covered Employees ,
Estate Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRA Rollovers ,
IRS ,
New Legislation ,
Pass-Through Entities ,
S-Corporation ,
Section 179 Property ,
Shareholders ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
Trump Administration
On April 9, 2020, the Secretary of the U.S. Department of Treasury (the “Secretary”) and the Internal Revenue Service (the “IRS”) issued Notice 2020-23 (the “Notice”), which extends the deadline for performance of a long list...more
4/13/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
e ,
EDD ,
Filing Deadlines ,
Franchise Tax Board ,
HDHP ,
Income Taxes ,
Installment Agreements ,
IRS ,
Relief Measures ,
State of Emergency ,
State Taxes ,
Tax Debt ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
On April 9, 2020, following issuance by the President of the United States of an emergency declaration under the Robert T. Stafford Disaster Relief and Emergency Assistance Act on March 13, 2020, the Secretary of the U.S....more
4/10/2020
/ Coronavirus/COVID-19 ,
Deadlines ,
Guidance Update ,
IRS ,
Like Kind Exchanges ,
Opportunity Zones ,
Secretary of the Treasury ,
Section 1031 Exchange ,
Stafford Act ,
Tax-Deferred Exchanges ,
Time Extensions ,
Trump Administration
Seyfarth Synopsis: On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). The CARES Act includes federal tax provisions that should provide relief to real...more
3/31/2020
/ Banks ,
Business Interruption ,
CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Families First Coronavirus Response Act (FFCRA) ,
Federal Loans ,
Financial Stimulus ,
Lenders ,
Lending ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
Small Business ,
Tax Relief
Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more
1/21/2020
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Construction Project ,
Economic Development ,
Exit Strategies ,
Final Rules ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Regulatory Standards ,
Safe Harbors ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Taxation ,
U.S. Treasury
Seyfarth Synopsis: On October 19, 2018, the U.S. Department of the Treasury released long-anticipated proposed regulations (the “Proposed Regulations”) relating to investments in Qualified Opportunity Zones (“QOZs”)....more
10/29/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
This is the third issue in a planned series of alerts designed to provide an in-depth analysis on topics related to tax reform.
Background
On November 2, 2017, House Republicans introduced the Tax Cuts and Jobs Act...more
12/19/2017
/ Business Taxes ,
Carried Interest ,
Corporate Taxes ,
EBITDA ,
Income Taxes ,
International Tax Issues ,
Legitimate Business Interest ,
Like Kind Exchanges ,
Local Taxes ,
Mortgage REITS ,
Pass-Through Entities ,
State Taxes ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Today marks just over a month since Donald Trump was elected as the next President of the United States. As each cabinet appointment is announced, we get more clues to help us predict which direction the Trump...more
12/13/2016
/ Affordable Care Act ,
Alternative Minimum Tax ,
Americans with Disabilities Act (ADA) ,
Cadillac Tax ,
Capital Investments ,
Capital Markets ,
Clean Power Plan ,
Clean Water Rule ,
Climate Action Plan ,
Coal Industry ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Taxes ,
Cross-Border Transactions ,
Cuba ,
DACA ,
DAPA ,
Defense Contracts ,
Department of Labor (DOL) ,
Deregulation ,
Dodd-Frank ,
EB-5 ,
Employer Mandates ,
Employment Eligibility Verification ,
Endangered Species Act (ESA) ,
Energy Policy ,
Environmental Protection Agency (EPA) ,
Executive Compensation ,
Exports ,
F-1 Visa ,
Foreign Subsidiaries ,
Form I-9 ,
Free Trade Agreements ,
Groundwater ,
H-1B ,
Healthcare Reform ,
Immigration Reform ,
Iran Sanctions ,
L-1 ,
Lending ,
Loans ,
Medicare ,
Minimum Salary ,
Multinationals ,
Paris Agreement ,
Popular ,
Presidential Elections ,
Renewable Energy ,
Repatriation ,
Repeal ,
Securities and Exchange Commission (SEC) ,
STEM ,
Tax Credits ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trans-Pacific Partnership ,
Trump Administration ,
Unpaid Overtime ,
US Army Corps of Engineers ,
USCIS ,
Venture Capital
Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more
11/7/2016
/ Cross-Border Transactions ,
Debt Financing ,
Debt-Equity ,
Disguised Sales ,
Disregarded Entities ,
Foreign Subsidiaries ,
Inversion ,
IRS ,
Multinationals ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Reclassification Rules ,
Recordkeeping Requirements ,
REIT ,
RICs ,
S-Corporation ,
Subsidiaries ,
U.S. Treasury
Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more
On December 18, 2015, President Obama signed into law the “Protecting Americans from Tax Hikes Act of 2015” (the “Act”), a substantial piece of tax legislation that, among many other provisions, contains significant changes...more
Several recent Supreme Court decisions have upended causation standards in the statutory alphabet soup of federal remedial rights. It is now clear that “but for” causation governs discrimination claims under the Age...more
10/21/2015
/ ADEA ,
Adverse Employment Action ,
Age Discrimination ,
Alternative Pleadings ,
Americans with Disabilities Act (ADA) ,
But For Causation ,
Corporate Counsel ,
Disability Discrimination ,
Family and Medical Leave Act (FMLA) ,
FRCP 8(d)(3) ,
Mixed Motive Cases ,
Race Discrimination ,
Retaliation ,
SCOTUS ,
Title VII
Christopher Pike: “That’s a technicality.”
Spock: “I am a [lawyer], sir. We embrace technicalities.”
Star Trek Into Darkness -
Arbitration is no longer the final frontier. Instead, arbitration is often the...more
Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more