News & Analysis as of

Depreciation Tax Cuts and Jobs Act

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

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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

Eversheds Sutherland (US) LLP

Proposed bill aims to postpone TCJA limits on business incentives

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

Eversheds Sutherland (US) LLP

No surprises under the tree as IRS concludes no normalization violation in use of revised composite depreciation rate lives to...

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

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

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

Gould + Ratner LLP

New Stimulus Allows Faster Depreciation of Certain Residential Rental Property Held by Electing Real Property Trades or Businesses

Gould + Ratner LLP on

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

McGlinchey Stafford

Winners And Losers In Like-Kind Exchange Final Regulations

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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

McGlinchey Stafford

IRS Proposes New Like-Kind Exchange Regulations

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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

McGlinchey Stafford

CARES Act Updates Tax Act’s Depreciation Period – Act Fast

McGlinchey Stafford on

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

McDermott Will & Emery

CARES Act Update: IRS Details How to Benefit from the Fix to the Retail Glitch

McDermott Will & Emery on

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

Lowndes

Real Estate Businesses Can Revoke 163(j) Election and Cash in on Bonus Depreciation Fix

Lowndes on

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

Eversheds Sutherland (US) LLP

Expensing 2.0 – Treasury and the Internal Revenue Service thoughtfully consider comments on the proposed § 168(k) regulations and...

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

Tonkon Torp LLP

Federal Tax Law Drafting Error Punishes Commercial Developers

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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

Rosenberg Martin Greenberg LLP

The Good, the Bad, and the Yet to be Defined

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

Eversheds Sutherland (US) LLP

IRS and Treasury issue final regulations on negative adjustments under UNICAP

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

Opportune LLP

Proposed Bonus Depreciation Regulations Favorable For Certain Energy Partnership Transactions

Opportune LLP on

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

Eversheds Sutherland (US) LLP

The more things change the more things remain the same–temporary guidance regarding bonus depreciation rules under section 168(k)

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

Mitchell, Williams, Selig, Gates & Woodyard,...

Repeal of the Personal Property Like-kind Exchange (… or, the Swap of §1031 for Increased Bonus Depreciation and Expensing)

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

Holland & Knight LLP

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on

• 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

Lowndes

Tax Reform Improves Expensing and Depreciation Rules

Lowndes on

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

Dickinson Wright

Tax Cuts and Jobs Act Expands Depreciation and Expensing

Dickinson Wright on

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

Whitman Legal Solutions, LLC

Tax Cuts and Jobs Act Changes Considerations in Section 1031 Exchanges

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

Hogan Lovells

Three new acts change tax and employee benefit rules and might require employer action

Hogan Lovells on

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

A&O Shearman

Impact of the Tax Cuts and Jobs Act on the Real Estate Industry

A&O Shearman on

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

Sheppard Mullin Richter & Hampton LLP

Real Estate Aspects of Tax Reform

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

Pillsbury Winthrop Shaw Pittman LLP

The Impact of the Tax Cuts and Jobs Act on LIHTC Investments

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

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