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Unlocking Success: The Strategy Behind Partnership Divisions for Tax Compliance

In the article that appeared in last month’s blog, I indicated that we utilize a structure that avoids the taxing authorities’ challenges to “drop and swap” transactions and, instead, that is structured to comply with an...more

Decoding Franchise Tax Board’s Hot Button Areas: Drops and Swaps and Post-Closing Refinancing

Those of us in California who give advice regarding the structuring of IRC Section 1031 like-kind tax-deferred exchanges of real property are well aware that the California Franchise Tax Board (FTB) has an active program of...more

Los Angeles "Mansion Tax" - Measure ULA, Its Impact on Property Owners, & Refunds

In November 2022, Measure ULA, commonly known as the "Mansion Tax," was passed into law by the City of Los Angeles voters. This tax applies to all categories of real estate, including commercial, industrial, and residential...more

IRS Further Extends Deadline for 1031 Exchanges Affected by the 2023 California Severe Winter Storms: Key Points You Need to Know

As a result of the severe winter storms, flooding and mud slides that began in California on January 8, 2023, on January 10, 2023, the IRS issued an initial extension of the 45- and 180-day deadlines for IRC §1031 exchange...more

F Reorganizations: The Good, The Bad, and the Wasteful

I. Introduction F reorganizations, much like the game of Othello, can take a minute to learn but a lifetime to master. They are often a critical part of structuring the purchase and sale of S corporations. As part of an F...more

IRS Extends Deadline for 1031 Exchanges Affected by the 2023 California Severe Winter Storms: Key Points You Need to Know

As a result of the severe winter storms, flooding and mud slides that began in California on January 8, 2023, the IRS has issued an extension of the 45- and 180-day deadlines for IRC §1031 exchange transactions. ...more

Harry Potter and the Chamber of Secret QSBS Exclusions

Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more

California Provides Path to Deduct State Income Tax for Calculating Federal Tax [UPDATED]

In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

California Provides Path to Deduct State Income Tax for Calculating Federal Tax

In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more

Californians Reject Prop. 15

While national attention over the past week has been focused on the outcome of the presidential election, Californians have also had their eyes on the fate of a number of propositions that made their way onto the November 3...more

IRS Grants Additional Relief for Qualified Opportunity Funds

On June 4, 2020, the IRS issued Notice 2020-39, which provides important relief to qualified opportunity zone investors (“QOZ Investors”), qualified opportunity funds (“QOFs”) and qualified opportunity zone businesses...more

IRS Extends Deadlines for IRC §1031 Exchange Transactions and Qualified Opportunity Fund Investments

On April 9, 2020, the IRS issued Notice 2020-23 providing sweeping tax filing and tax payment deferral until July 15, 2020. This relief includes extensions of the 45- and 180-day deadlines for IRC §1031 exchange transactions...more

Final Regulations on Opportunity Zones: An In-Depth Guide

Final regulations on opportunity zones were issued by the IRS on December 19, 2019. There are a few major changes and clarifications in the final regulations compared to the prior proposed regulations, a summary of which is...more

The Tax Joys of Opportunity Zones

New proposed regulations on opportunity zones were issued in May of 2019. We are happy to provide you with this eBook, written by Greenberg Glusker Partner, Schuyler (Sky) M. Moore, which incorporates these proposed...more

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