Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
Tax Developments Affecting Health Care Organizations and Investor-Owned Hospital Companies
The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
On December 17, 2021, the IRS released Private Letter Ruling 202150003 where it concluded that a Taxpayer would not violate the normalization rules if it ratably amortized its Protected EDIT (defined below) pursuant to an...more
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure: ..Allows controlled...more
The stimulus package passed last month may help certain Electing Real Property Businesses by including a provision that allows a shorter depreciation period for residential rental property acquired prior to January 1, 2018. ...more
The Treasury Department and the IRS received 21 written comments in response to the like-kind exchange proposed regulations (see our earlier alert). The recently issued final IRS like-kind exchange regulations adopt some...more
The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more
Before the enactment of the 2017 Tax Cuts and Jobs Act (TCJA), qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property had a 15-year recovery period for depreciation...more
Under the Tax Cuts and Jobs Act of 2017 (TCJA), qualified improvement property (QIP) was unintentionally classified as nonresidential real property and therefore did not qualify for bonus depreciation. The Coronavirus Aid,...more
The 2017 Tax Cuts and Jobs Act introduced a new Section 163(j) limitation on deducting business interest expense. Specifically, businesses could only deduct net business interest in any given year equal to 30% of adjusted...more
On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more
The Tax Cuts and Jobs Act, signed into law in December 2017, promised radical changes to the federal tax code. Many of its goodies were aimed at the real estate industry, but because of a critical drafting error, many...more
The Tax Cuts and Jobs Act (“TCJA”) provided the most comprehensive update to the tax code in over two decades. Of the many changes the TCJA provided, Sections 1400Z-1 and 1400Z-2 of the IRC are of the most heavily discussed...more
On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes...more
President Trump signed into law the Tax Cuts and Jobs Act (the “TCJA”) on December 22, 2017. Included in the TCJA were amendments to IRC §168(k), which permits taxpayers to expense 100% of the costs of certain qualified...more
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more
One of the lessor discussed items in the recently enacted Tax Cuts and Jobs Act (“TCJA”) has been the change to Section 1031, limiting the like-kind exchange provisions to exchanges of real property only. Section 1031 of...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
The Tax Cut and Jobs Act made several key changes to the expensing and depreciation rules, which will be a boon for Senior Living businesses that tend to be real estate heavy....more
The Tax Cuts and Jobs Act (“TCJA”) is a treasure trove of tax law changes which may (at least temporarily) reduce the tax liability of businesses. One area of tax benefit for businesses is the TCJA expansion of the expenses...more
In a “Sizing Up in Violins and Investment Real Estate,” another post in the Orchestrating Real Estate series, I discussed how buying increasingly larger (and more expensive) violins compares to real estate investments. I...more
Congress and the Administration have been busy recently, enacting not only the "Tax Cuts and Jobs Act" or "TCJA" on December 22, 2017, but also a Continuing Resolution on January 23, 2018, and the Bipartisan Budget Act of...more
On December 22, 2017, H.R.1, commonly referred to as the Tax Cuts and Jobs Act (“Tax Act”) was signed into law. The Tax Act made the most significant changes to the U.S. tax code since 1986, and will have an effect on...more
On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (TCJA), the most extensive overhaul of the United States tax regime in over thirty years. The new tax laws will have a significant impact upon...more
The Tax Cuts and Jobs Act contains changes impacting the LIHTC Program. While the low-income housing tax credit program emerged largely unscathed, the reduction in corporate tax rates will reduce equity pricing. ...more