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Debt Tax Planning

McDermott Will & Schulte

Receiving Debt-Financed Distributions From a QOF: IRS Allows Significant Flexibility (And Some Traps)

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

Farrell Fritz, P.C.

Internal Revenue Service Warns of “Mills” Taking Advantage of Taxpayers With Offer in Compromise (“OIC”) Program

Farrell Fritz, P.C. on

In a recent news release (available here), the Internal Revenue Service (“IRS”) warned taxpayers about promoters claiming their services are needed to resolve unpaid taxes owed to the IRS....more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

ASKramer Law on

What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

Winstead PC

[Virtual Half-Day Seminar] Real Estate Startup - April 18th, 9:00 am - 12:15 pm CST

Winstead PC on

On April 18, join Winstead attorneys Trip Dyer, Ben Gehlbach, Daniel Bell-Garcia, Jacob Loehr, Matt Dzura, and Cole Gearhart, along with Whitley Penn Partner Shea Krachek, for our Real Estate Startup half-day virtual seminar....more

Cozen O'Connor

Debt Cancellation Income Arising in Connection with the Ownership of Real Estate

Cozen O'Connor on

Part I of this paper explored how the income tax rules applied to taxpayers recognizing cancellation of indebtedness income. The paper laid out the myriad rules applicable to solvent and insolvent taxpayers, how to ascertain...more

Best Best & Krieger LLP

Best in Law: Take Some Time with Your Minute Book

BB&K Business Attorney Brian Reider Discusses the Importance of Minute Books in the Southern California Newspaper Group - Looking back at the year, one recurring theme emerges with corporate clients and their...more

Herbert Smith Freehills Kramer

Debt-Equity Dashed Expectations: Treasury and the Service Retain Onerous Section 385 Regulations

On Nov. 4, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) published final debt-equity regulations (the Final Regulations) and an advance notice of proposed rulemaking (the...more

McNees Wallace & Nurick LLC

McNees Insights – Estate Planning: March 2019

Estate Planning for Real Estate Owners - Estate planning for valuable, illiquid assets presents a variety of challenges. With respect to real estate, planning challenges can be compounded due to fractional ownership, outside...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Fenwick & West LLP

Section 385 Proposed Regulations

Fenwick & West LLP on

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

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