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Safe Harbors Internal Revenue Code (IRC) Tax Liability

Freeman Law

Penalties for Failures with Respect to Forms 1099 and Other Information Returns

Freeman Law on

Section 6721 of the Internal Revenue Code imposes a penalty on any person who fails to file a Form 1099 or other information return to the IRS by the required filing date, fails to include all information required to be shown...more

Cadwalader, Wickersham & Taft LLP

Tax Court Adopts Broad Reading of Profits Interests Safe Harbor

Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more

McDermott Will & Emery

The Working Capital Safe Harbor

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

The Nonqualified Financial Property Limitation

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Orrick, Herrington & Sutcliffe LLP

New IRS Ruling on Port and Airport Leases

In a private letter ruling (PLR 201918008) publicly released earlier this week, the IRS addressed the statutory safe harbor relating to the allowable term for leases of port and airport facilities financed with tax-exempt...more

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