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Internal Revenue Service 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

Bowditch & Dewey

Do the Retirement Plan Provisions in Your Trust Still Align with Your Estate Planning Goals Following Updates to the SECURE Act?

Bowditch & Dewey on

Following the IRS’ finalization of the SECURE Act regulations on July 18, 2024, it is a good time to review the retirement benefit provisions of your trust to make sure they still align with your estate planning goals....more

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

Pra Dizer Adeus (To Say Goodbye) – A Homage to Sergio Mendes and a Little Bit About Tax Planning for PPLI for Trial Lawyers

Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more

Levenfeld Pearlstein, LLC

Practical 1031: What is an Internal Revenue Code Section 1031 Like-Kind Exchange?

Question: What is an Internal Revenue Code Section 1031 Like-Kind Exchange? Answer: Section 1031 of the Internal Revenue Code allows a taxpayer who owns business or investment real estate to “exchange” the real estate the...more

Williams Mullen

[Event] 2024 Fall Tax Forum - November 20th, Richmond, VA

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Join Williams Mullen attorneys for our Fall Tax Forum on Wednesday, November 20th, where our speakers will present on certain federal income tax issues with respect to real property transactions including 1031 exchanges, drop...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

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Holland & Knight LLP

IRS Rules 3 Utilities Cannot Reduce NOL Carryforwards for Tax Allocation Payments

Holland & Knight LLP on

Following the initial public release of private letter ruling (PLR) 20242002 as part of a state rate proceeding, on June 28, 2024, the IRS publicly released that ruling, as well as two companion rulings obtained by other...more

Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

Holland & Knight LLP on

The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Holland & Knight LLP

IRS: Use of "Attrition Allowance" to Calculate Rate Base Violates Normalization Consistency Rules

Holland & Knight LLP on

Consistent with a state commission's existing regulatory policy, a utility's rate base for the first two years of the three-year rate cycle was computed using traditional cost-of-service/rate of return principles....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

Fisher Phillips

2024 Employee Benefit Limits Plus 6 Best Practices for Employers

Fisher Phillips on

Get Ready For The New Year Ahead - Employees can contribute more pre-tax dollars next year to their retirement savings accounts, including 401(k) and 403(b) plans, according to an IRS announcement made on November 1. Your...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Keating Muething & Klekamp PLL

Benefits Monthly Minute - January 2023

The Senate ushered in the New Year with a bang by passing SECURE 2.0 on December 22, 2022. SECURE 2.0 includes many updates to the sweeping changes brought about under 2019’s original SECURE Act legislation. The following are...more

McDermott Will & Emery

Weekly IRS Roundup December 5 – December 9, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022...more

Jackson Lewis P.C.

2023 Cost of Living Adjustments for Retirement Plans

Jackson Lewis P.C. on

The Internal Revenue Service recently announced its cost-of-living adjustments applicable to dollar limitations on benefits and contributions for retirement plans generally effective for Tax Year 2023 (see IRS Notice...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

Holland & Knight LLP

Planning for the Future: Estate and Tax Planning with Digital Assets

Holland & Knight LLP on

Cryptocurrencies are becoming a larger component of investors' portfolios, especially for millennials and Generation Z, who collectively make up 94 percent of cryptocurrency buyers. While it may seemingly be too early for...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 & Emery

Weekly IRS Roundup December 27 – December 31, 2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 27, 2021 – December 31, 2021... December 27, 2021: The IRS published a news release...more

McDermott Will & Emery

Weekly IRS Roundup December 13 – December 17, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 13, 2021 – December 17, 2021. December 13, 2021: The IRS published a memorandum...more

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