In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more
Just days before we all sat down to eat our Thanksgiving dinners, the Treasury Department gave us something else to digest: final like-kind exchange regulations. These regulations define “real property” for purposes of Code...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
On June 11, 2020, the U.S. Treasury Department released highly anticipated proposed Treasury Regulations on like-kind exchanges under Section 1031 (the “Proposed Regulations”). The Proposed Regulations provide much-needed...more
On June 11, 2020, the Internal Revenue Service (the “IRS”) issued proposed regulations that define the term “real property” for purposes of Section 1031 of the Internal Revenue Code of 1986, as amended (the “Code”)....more
Summary - On June 11, 2020, the Treasury Department released proposed regulations regarding like kind exchanges under Internal Revenue Code section 1031 (“1031 Exchange”). The regulations clarify a number of outstanding...more
The Taxable Exchange- As a general rule, a taxpayer’s exchange of one property for another property is treated as a taxable event; the gain realized by the taxpayer – meaning the amount by which the fair market value of...more
On April 11, 2019, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2019-18, creating a safe harbor that allows professional sports teams to treat trades of personnel contracts (including contracts for...more
The Internal Revenue Service (“IRS”) issued Revenue Procedure 2019-18 that provides a safe harbor provision for professional sports teams that allows a team to treat the value of a traded player, draft pick, or staff members,...more
On December 22, 2017, Congress enacted the Tax Cuts and Jobs Act (the Act) which made numerous changes to the Internal Revenue Code (the Code) and incentivized certain investments in qualified opportunity zones. The Act...more
For years, Code § 1031 has been a popular way to defer taxation on the sale of capital gain assets. However, Code § 1031 has significant requirements, including complex timing and identification requirements and a requirement...more
Qualified Opportunity Zones were included as part of the Tax Cuts and Jobs Act which became law in December 2017. The zones were originally introduced as the Investing in Opportunity Act sponsored by South Carolina Senator...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more