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Real Estate Transfers Internal Revenue Service

Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

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The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Miller Canfield

Amount Realized and Cost Basis in a Property Transaction With Hard-to-Value Property

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In Private Letter Ruling 202352011 (December 30, 2023), the taxpayer asked the IRS to determine the amount that it will realize in a property transaction. The taxpayer will receive the property in an arm’s length exchange...more

Stoel Rives LLP

What Out-of-State Buyers Should Know About California Real Estate Transfer Taxes

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As Benjamin Franklin once said, “Nothing in this world can be said to be certain, except death and taxes.” For out-of-state buyers unfamiliar with California’s transfer tax system, there are a few things to know to avoid a...more

Greenberg Glusker LLP

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

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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

Perkins Coie

More Than a Mansion Tax: L.A.’s Measure ULA Will Address the City’s Housing Crisis

Perkins Coie on

Los Angeles’ United to House LA Measure (Measure ULA), enacted by city voters in November 2022, implements a significant new transfer tax on high-value real estate transfers or sales throughout the city of Los Angeles....more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall: You Sell Real Estate for $1

Someone may have told you a story along these lines: Years ago, my grandfather bought land along the shore in (fill in a desirable resort area) for $1,000. He built a vacation home on the property for $50,000 and his family...more

Dorsey & Whitney LLP

Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property

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Many Canadian companies and individuals own U.S. real property interests through a U.S. corporation. The Foreign Investment in Real Property Tax Act (“FIRPTA”) regime imposes a withholding tax (currently at a rate as high as...more

Cozen O'Connor

IRS Issues Final Regulations Governing 1031 Exchanges – The “Like Kind” Standard Defined

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On November 23, 2020, Treasury and the IRS issued final regulations governing tax-deferred exchanges of like-kind real property under Section 1031 of the Internal Revenue Code (the Code). These final regulations (T.D. 9935 )...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

Obermayer Rebmann Maxwell & Hippel LLP

New IRS Guidance for Like-Kind Exchanges

In 2017, the Tax Cuts and Jobs Act modified the rules for like-kind exchanges to apply only to real property not held primarily for sale. Prior to the Tax Cuts and Jobs Act, exchanges of machinery, equipment, vehicles,...more

Miles & Stockbridge P.C.

Bankruptcy Court Within Fourth Circuit Permits Fraudulent Conveyance Claims to Move Forward Under IRS 10-Year Reach Back Period

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A recent opinion by the United States Bankruptcy Court for the Western District of North Carolina kept alive a bankruptcy trustee’s fraudulent conveyance claims based on, in part, the Internal Revenue Code (“IRC”) 10-year...more

Williams Mullen

Section 83(b) Elections: Limited COVID-19 Relief, but Keep Your Records

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A limited extension, until July 15, 2020, is available for Internal Revenue Code (“Code”) Section 83(b) elections otherwise due on or after April 1, 2020, and before July 15, 2020. It will be especially important for...more

McDermott Will & Emery

Weekly IRS Roundup February 10 – 14, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10 – 14, 2020. February 10, 2020: The IRS issued a revenue ruling providing guidance...more

Allen Matkins

California Office of Tax Appeals Upholds Taxpayer Friendly "Drop and Swap" Case

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On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more

Katten Muchin Rosenman LLP

2019 Year-End Private Wealth Advisory

In 2019, the Tax Cuts and Jobs Act (the Act) and its resulting tax reform continued to dominate the planning landscape. As outlined in our 2018 Year-End Estate Planning Advisory, the Act made significant changes to individual...more

McDermott Will & Emery

Weekly IRS Roundup June 3 – 7, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Adler Pollock & Sheehan P.C.

Insight on Estate Planning - February/March 2019: Basis consistency rules come into play when inheriting property

If a person is in line to inherit property from a parent or other loved one, it’s critical to understand the basis consistency rules. Tax law provides that the income tax basis of property received from a deceased person...more

Foster Garvey PC

The Seventh Circuit Affirmed the U.S. Tax Court in Exelon Corporation v. Commissioner – Having Expert Tax Advisors on Your Team...

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In Exelon, the Seventh Circuit held that exchanges by Exelon Corporation (“Taxpayer”) of nuclear power plants for long-term leasehold interests in power plants located in other states were not exchanges qualifying for...more

Farrell Fritz, P.C.

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

Farrell Fritz, P.C. on

Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Benesch

Perspectives - August/September 2016

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We’ve all heard about India’s rape crisis, but not everyone knows that it’s the result of the larger problem of gender inequality. According to UNICEF, India is the worst place to be born a girl. The birth of a baby girl is...more

McNees Wallace & Nurick LLC

IRS Proposes New Rules for Valuing Interests in Family-Owned Businesses

Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more

Stoel Rives LLP

Energy Tax Law Alert: IRS Expands Safe Harbor for Transfers of Property to Transmission Providers

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The IRS on June 10 issued Notice 2016-36, which expands a safe harbor allowing certain transfers of property to regulated public utilities to be treated as nontaxable contributions of capital to a corporation, rather than as...more

Tucker Arensberg, P.C.

Fiduciary Alert: IRS Again Extends Time for Consistent Basis Reporting via Form 8971 until June 30, 2016

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Effective March 23, 2016, the Treasury Department and Internal Revenue Service published Notice 2016-27, once again extending, until June 30, 2016, the deadline for executors and other persons to complete and file Form 8971...more

Williams Mullen

Consistent Basis Reporting Update: Treasury Issues Proposed Rules on Portability Returns, Final Values, and After-Discovered...

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On March 4, 2016, the U.S. Department of the Treasury released both temporary and proposed regulations (the “Proposed Regulations”) on the consistent basis and reporting requirements between a decedent’s estate and persons...more

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