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
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 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
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
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