News & Analysis as of

Pass-Through Entities Tax Deferral

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

Rivkin Radler LLP on

In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

Rivkin Radler LLP on

Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR PART IV

Structuring the family business. This is a solution for every taxpayer to triple a Roth contribution. #assetprotection #estateplanning #retirementplanning #employeebenefits #entrepreneur #taxplanning...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR PART IV

Nowotny On Death and Taxes episode #26, The Accidental Entrepreneur Part IV - Creating the Family Pension Plan speaks to a solution for every taxpayer to triple a Roth contribution....more

Obermayer Rebmann Maxwell & Hippel LLP

TAX ALERT: Final QOZ Regulations: 8 Important Changes You Should Know

The IRS issued final QOZ regulations at the end of 2019, almost two years after Qualified Opportunity Zones (“QOZs”) were introduced to investors in the 2017 Tax Cuts and Jobs Act. These regulations finalized the proposed...more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

Obermayer Rebmann Maxwell & Hippel LLP

Qualified Opportunity Funds: Rental Real Estate Investments – Active Conduct of Trade or Business Test

One of the hottest topics in the real estate right now is the federal Qualified Opportunity Zone program. This program caught the interest of real estate investors because of the potential tax breaks available to those who...more

Foster Garvey PC

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Foodman CPAs & Advisors

Did you know that IRS is running 35 Campaigns?

In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more

Orrick, Herrington & Sutcliffe LLP

International Provisions in U.S. Tax Reform - A Closer Look

On December 15, the U.S. Congress issued its final version of tax reform via the Conference Report Bill (the “Bill”), which was passed by both Houses of Congress. The Bill represents a compromise of two prior tax reform ...more

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