On 3 July 2025, the House passed the Senate’s version of H.R. 1, the budget reconciliation bill formerly known as the “One Big Beautiful Bill Act” (the Act). President Trump signed the Act into law on 4 July 2025. The...more
7/15/2025
/ Business Taxes ,
Corporate Taxes ,
Employee Benefits ,
Energy Policy ,
Estate Tax ,
International Tax Issues ,
One Big Beautiful Bill Act ,
Real Estate Investments ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Reform
President Trump used his 4 March 2025 address to the joint session of Congress to remind the American public and Congressional leaders that he is serious about adding his imprimatur to the tax code—and in the process adding...more
3/7/2025
/ Budget Reconciliation ,
Business Taxes ,
Corporate Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Legislative Agendas ,
Proposed Legislation ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
Overview - On Monday, 11 March 2024, the Biden administration released the president’s budget request (PBR) for fiscal year 2025 (FY2025), as well as the “Greenbook” containing explanations of the various revenue proposals in...more
3/25/2024
/ Biden Administration ,
Capital Gains ,
Excise Tax ,
Federal Budget ,
GILTI tax ,
Green Book ,
Inflation Reduction Act (IRA) ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Policy
SENATE OUTCOMES WILL SHAPE THE BIDEN TAX AGENDA - The waiting is over and Joe Biden is the declared winner of the presidential election. Because both Senate races in Georgia have gone to run-offs we won’t know until January...more
The tax code could play a key role as discussions about a tax stimulus package intensify -
The coronavirus has taken over Washington, D.C., if not through infection, then through a focus on policy prescriptions to help the...more
Almost exactly two years after enactment in the Tax Cuts and Jobs Act, Treasury has released final regulations on the Opportunity Zone (“OZ”) tax incentive. ...more
GSA Properties Open Window of Opportunity for Investors with Capital Gains -
A new mandate requiring the federal government to sell property it no longer uses or needs creates significant “opportunities” for investors with...more
The plan would tax all capital gains as ordinary income; end deferral of capital gains tax for the wealthy -
Senate Finance Committee Ranking Member Ron Wyden (D-OR) recently released a proposal, “Treat Wealth Like Wages,”...more
INTRODUCTION -
On July 15, 2019, the staffs of the Securities and Exchange Commission (“SEC”) and the North American Securities Administrators Association issued a joint statement (the “Staff Statement”) to assist...more
The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for many industries, as we discussed soon after the TCJA became law. The first set of proposed regulations...more
The Senate Finance Committee has launched a new effort to consider the fate of dozens of temporary tax provisions (or “extenders”) that have expired in recent years, as well as other provisions slated to expire in 2019 and...more
Restoring accountability measures stripped during tax reform could be good news for those concerned about gentrification but may result in reputational risks and additional costs for OZ Funds -
As we anticipated in our...more
The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more
After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more
5/6/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
Sen. Tammy Baldwin (D-WI) and Rep. Bill Pascrell (D-NJ) recently reintroduced the “Carried Interest Fairness Act of 2019” (the “Act”). The sponsors claim that the Act would “provide for the proper tax treatment of personal...more
In December 2017, Congress enacted The Tax Cuts and Jobs Act (the “Tax Cuts Act”). Included in that tax legislation is what has come to be called the opportunity zone incentive (“OZ Incentive”): a host of dramatic new tax...more
A new federal tax incentive enacted in the 2017 tax reform package may provide a boost to many new and used (when refurbished) facilities and equipment used in the agribusiness industry. This could include buildings, silos,...more
The Tax Cuts and Jobs Act (the “Act”) created a significant new tax incentive for taxpayers that invest capital gains in Qualified Opportunity Funds (each a “QOF” and collectively, “QOFs”). Investors can defer paying tax on...more
10/30/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Deferral
The Internal Revenue Service (“IRS”) has released proposed regulations explaining how taxpayers should calculate the Section 199A deduction for qualified business income. ...more
Tax Reform Slashes Deductions for Settlements Paid to Government Agencies for Violations and Investigations - IRS Requests Comments by May 18 - Businesses making payments to governments and governmental entities on or after...more
Secretary Mnuchin and Director Mulvaney have peaceably resolved their differences over the review process of tax regulations. Will greater OMB review of Treasury regulations be a positive or a negative for taxpayers? ...more
The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) are picking up the pace in releasing substantive guidance regarding implementation of the Tax Cuts and Jobs Act (“TCJA”), passed by Congress...more
Incentives for Investments in Low Income Communities - Deferred taxes on capital gains and elimination of taxes on gains from Opportunity Fund investments are intended to attract investors into the Opportunity Zone program....more
The tax reform bill signed into law by President Trump on December 22, 2017, taxes U.S. shareholders on their share of the previously untaxed deferred income of foreign corporations. Known as “deemed repatriation,” this tax...more
When President Trump signed the Tax Cuts and Jobs Act (“TCJA”) on December 22, 2017, it wasn’t the grand finale of the tax reform process — it was merely the end of the first act. Already, Congress has begun considering...more