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Investors › Limited Liability Company (LLC) › Internal Revenue Service

Kohrman Jackson & Krantz LLP

Combining Membership Interest Purchase Agreements & 1031 Exchanges to Maximize Tax Efficiency in Real Estate Deals

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The intersection of real estate transactions and tax strategy has long been a focal point for investors seeking to optimize returns while minimizing liabilities. Two powerful tools in this arena – the Membership Interest...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

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At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Rivkin Radler LLP

Sale of Partnership Interests . . . In the Ordinary Course of Business?

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What Is It? Where one stands on an issue of tax law may depend upon context and perspective, including the facts and circumstances one finds relevant, and whom one is counseling or representing. Tax advisers often find...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

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Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

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BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

Perkins Coie

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

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New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

Cooley LLP

Alert: New Tax Court Decision Opens the Door for Tax Planning for Non-US Investors into US LLCs

Cooley LLP on

On July 13, 2017, the US Tax Court issued a decision which may provide non-US investors more flexibility and potentially better tax outcomes with respect to structuring their investments into US LLCs and partnerships....more

Miles & Stockbridge P.C.

Fourth Circuit Finds Disguised Sale of VA Land Conservation Tax Credits

Miles & Stockbridge P.C. on

In Route 231, LLC v. Commissioner, 117 AFTR 2d 2016-XXXX (4th Cir. 2016), the U.S. Court of Appeals for the Fourth Circuit held that certain funds received by the taxpayer constituted income from the sale of Virginia land...more

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