News & Analysis as of

Internal Revenue Service Capital Gains Tax Deferral

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Kohrman Jackson & Krantz LLP

Navigating Interest Income in 1031 Exchanges: Strategic Considerations for Tax Deferral

As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more

Kohrman Jackson & Krantz LLP

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

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

Bricker Graydon LLP

“S” Corp? Law Change May Make an ESOP More Appealing

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The SECURE 2.0 Act of 2022 (“SECURE 2.0”) made numerous changes to the complex web that makes up U.S. retirement plan laws. Of interest to S corporations that may be considering an employee stock ownership plan (“ESOP”) is...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

Rivkin Radler LLP on

Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

Rivkin Radler LLP

The President’s 2024 Federal Budget: “Reforming” the Taxation of High-Income Taxpayers

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The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year. Among other things, the proposed federal budget affords the President an...more

Rivkin Radler LLP

S Corps with Real Property: Separating Shareholders & Partnership Envy

Rivkin Radler LLP on

Tax Alchemy? How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Oberheiden P.C.

Can You Defer Taxes on Your Crypto Investments? Ten Tips for What You Need to Know

Oberheiden P.C. on

U.S. taxpayers have an obligation to both report their cryptocurrency transactions to the IRS and pay taxes on it. Individuals who hold on to their cryptocurrencies as an investment are subject to short- and long-term capital...more

McDermott Will & Schulte

The Nonqualified Financial Property Limitation

McDermott Will & Schulte on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

Rivkin Radler LLP on

Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

Gray Reed

IRS Issues New Rules for Gain Deferral in Business Exchanges of Real Property

Gray Reed on

Even if you are not a tax professional, many people have heard of a 1031 exchange or like-kind exchange. This tax deferral provision has been a permanent part of the Internal Revenue Code for a long time. Usually, if a...more

Stinson LLP

IRS Issues Final Carried Interest Regulations

Stinson LLP on

The tax treatment of carried interests was changed with the enactment of Section 1061 of the Internal Revenue Code as part of the 2017 Tax Cuts and Jobs Act. After issuing proposed regulations last summer, the Internal...more

Gerald Nowotny - Law Office of Gerald R....

THE WONDER YEARS WEBINAR

Loan Regime Method of Split Dollar Life Insurance - This webinar covers: What is Split Dollar? Loan Method versus Economic Benefit. Leverage Split Dollar Rollout. Planning examples using Split Dollar....more

Pierce Atwood LLP

IRS Provides Relief on Opportunity Zone Deadlines

Pierce Atwood LLP on

On June 4, 2020, in response to the ongoing COVID-19 pandemic, the IRS issued Notice 2020-39 to provide relief regarding various deadlines applicable to the federal opportunity zone program....more

Orrick, Herrington & Sutcliffe LLP

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

Polsinelli on

Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”).  These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more

Seyfarth Shaw LLP

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

Seyfarth Shaw LLP on

Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

Lowndes

Industry News Briefs

Lowndes on

Happy New Year! Did I Miss My Chance at Opportunity Zones? Opportunity zones were introduced in 2017 as part of President Trump’s tax reform bill. Taxpayers with capital gains can receive several tax benefits if the...more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

Blank Rome LLP

IRS Publishes Final Opportunity Zone Regulations

Blank Rome LLP on

On December 19, 2019, the Treasury Department and Internal Revenue Service (the “IRS”) released final regulations for the opportunity zone (“OZ”) program to refine and clarify certain aspects of the first two sets of proposed...more

King & Spalding

IRS and Treasury Release Final Opportunity Zone Regulations

King & Spalding on

On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Stinson LLP

Opportunity Zone Final Guidance

Stinson LLP on

The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary....more

McDermott Will & Schulte

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Partridge Snow & Hahn LLP

Final Opportunity Zone Treasury Regulations Released

On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...more

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