News & Analysis as of

Capital Gains

Opportunity Zones Could Spur Private Investment in Low Income Areas

by Harris Beach PLLC on

The latest tax reform passed in the Tax Cuts and Jobs Act (TCJA) created a new incentive which will impact real estate development in low-income communities by creating “Qualified Opportunity Zones.” The impact of these...more

Foreign Partners Victims of Tax Reform - Tax Update, Volume 2018, Issue 1

by Pepper Hamilton LLP on

More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more

LATIN AMERICA & THE CARIBBEAN: A Legal Guide for Business Investment and Expansion - Colombia

1 .What role does the government of Colombia play in approving and regulating foreign direct investment? Foreign direct investment (FDI) in Colombia is subject to registration with the Colombian Central Bank (Banco de la...more

Bracewell Tax Report - March 2018

by Bracewell LLP on

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Opportunity Zones - A Golden Opportunity?

by K&L Gates LLP on

Incentives for Investments in Low Income Communities - Deferred taxes on capital gains and elimination of taxes on gains from Opportunity Fund investments are intended to attract investors into the Opportunity Zone program....more

Key Federal Inflation-Adjusted Amounts for 2018

by Charles (Chuck) Rubin on

In Rev.Proc. 2018-18, the IRS has released various tax rates, brackets, and threshold amounts for 2018, incorporating inflation adjustments and the new tax act....more

Eleventh Circuit Holds Forfeited Deposit On Terminated Sale Is Ordinary Income

by Fox Rothschild LLP on

In CRI-Leslie, LLC, the Eleventh Circuit confronted whether a taxpayer is entitled to capital gains treatment for a forfeited deposit on the sale of land. CRI-Leslie, LLC, Donald W. Wallace, Tax Matters Partner v....more

California’s Proposed Opportunity Zones Announced

The Tax Cuts and Jobs Act creates a new tax incentive to stimulate economic development in certain low-income communities known as “Opportunity Zones.”  This program will allow businesses and commercial projects located in...more

2017 Tax Act: Choice of Entity

by White and Williams LLP on

We recently prepared an alert on the new 20% qualified business income deduction that was added by the 2017 Tax Act. We have received many questions from our clients and friends about whether, notwithstanding the QBI...more

Avoiding Development Disasters: Land Inventory and 1031 Exchanges

The ability to defer taxes through a 1031 Exchange can make or break a real estate transaction. But federal tax law does not treat all real estate owners equally. Under IRC Section 1031(a)(2), real property held “primarily...more

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

by Perkins Coie on

New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

Treasury and IRS to Clarify New Carried Interest Rules

by Clark Hill PLC on

On March 1, the IRS and Treasury announced their intent to issue regulations addressing the new carried interest rules enacted as part of tax reform. More specifically, they intend to clarify that the new rules apply to...more

Regulatory Monitor: Private Funds Update

by K&L Gates LLP on

The Tax Cuts and Jobs Act – Material Impact on Private Funds - On December 22, 2017, the president signed the tax reform bill formerly known as the Tax Cuts and Jobs Act (the TCJA). While the TCJA will impact many types of...more

Permanent or Temporary Deferral of Tax on Gains: Opportunity Zones

by Ballard Spahr LLP on

The new tax law, known as the Tax Cuts and Jobs Act, allows states, the District of Columbia, U.S. possessions, and Puerto Rico to designate Qualified Opportunity Zones to encourage new capital investment in low income census...more

2018 Federal Budget: Selected Tax Measures

On February 27, 2018, the Minister of Finance introduced Canada’s 2018 Federal Budget (2018 Budget). The 2018 Budget includes measures affecting the taxation of passive income earned by private corporations, as was expected,...more

Big Changes to 1031 Exchanges, But Not for Real Estate (Yet)

by Tonkon Torp LLP on

Section 1031 of the tax code allows sellers of investment property to defer capital gains if the proceeds are reinvested in "like kind" property within certain timeframes. Prior to 2018, 1031 exchanges could be used for many...more

Capital Gain Or Ordinary Income? Establishing Intent

by Farrell Fritz, P.C. on

Last week’s post considered the risk assumed by a taxpayer that ignores the plain meaning of a Code provision (the definition of “capital asset”) in favor of a more “rational” – favorable? – interpretation of that...more

U.S. Tax Reform – What It Means For The Gaming And Hospitality Industry

by Dickinson Wright on

Against all odds, Congress, on a straight party-line vote, enacted the most significant tax reform the U.S. has witnessed in more than 30 years. The tax reform legislation, known as the “Tax Cuts and Jobs Act,” significantly...more

Tax Reform's New Incentives for Investments in Low-Income Communities: Part 3 - Key Benefits for Investing Taxpayers and a Review...

by Holland & Knight LLP on

• Part 1 and Part 2 of this series of Holland & Knight alerts described a new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." • In Part 3,...more

2017 New Tax Law: Pass Through Provisions

by Blank Rome LLP on

On December 20, 2017, Congress passed its comprehensive tax reform bill, the Tax Cuts and Jobs Act (“the Act” or “the Bill”), which was signed into law by President Trump on December 22, 2017. The Bill represents one of the...more

“Interpreting” The Code’s Plain Text

by Farrell Fritz, P.C. on

What Does It Mean? The Tax Cuts and Jobs Act[1] has now been in effect for fifty days. During this relatively brief period, many tax professionals have pored over the statutory language, as well as the Joint Explanatory...more

Tenga cuidado con las Ventas o Transferencias del 10% de la Propiedad en una Corporación Extranjera

by Foodman CPAs & Advisors on

La "Ley de reducción de impuestos y empleos" (la "Ley") contiene una provisión que es una "acompañante hermana" de la Deducción por Dividendos Recibidos (DRD) que implica ventas o transferencias que envuelven un 10% de la ...more

Beware of Sales or Transfers of 10% ownership in a Foreign Corporation

by Foodman CPAs & Advisors on

The “Tax Cuts and Jobs Act” (the “Act”) contains a provision that is a “sister companion” to the Deduction for Dividends Received (DRD) that involves sales or transfers that involve specified 10% ownership in foreign...more

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

by McNair Law Firm, P.A. on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Disposal of shares by non-residents: Gaining the capital perspective

by Hogan Lovells on

Capital gains tax (CGT) was introduced to the Income Tax Act (the Act) on 1 October 2001. The basis from which it operates is that if a capital asset is sold at a profit, the profit is subject to CGT, and if it is sold at a...more

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