Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...more
2/3/2025
/ Capital Gains ,
Debt ,
Internal Revenue Code (IRC) ,
Investment ,
Investment Funds ,
IRS ,
Partnerships ,
Qualified Opportunity Funds ,
Tax Credits ,
Tax Incentives ,
Tax Liability ,
Tax Planning
Rev. Proc. 2020-23 eases restrictions on partnerships’ ability to file amended tax returns and issue amended Schedules K-1 in order for their partners to avail themselves of the retroactive tax relief provided by the CARES...more
The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) relaxes the section 163(j) business interest expense limitation for tax years beginning in both 2019 and 2020. Intended to help taxpayers incurring...more
On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more
The newly enacted version of section 163(j) limits deductions for business interest expense. Although the prior version of section 163(j) applied almost exclusively to US corporations with non-US parents, the new version of...more