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Internal Revenue Service Tax Planning Real Estate Investments

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.  
Husch Blackwell LLP

OBBBA Extends, Modifies Opportunity Zone Program

Husch Blackwell LLP on

One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more

Troutman Pepper Locke

The One Big Beautiful Bill Act: Analysis of Key Provisions for the Real Estate Industry

Troutman Pepper Locke on

On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert released following the passage by the House of...more

Sullivan & Worcester

Sullivan & Worcester Submits Comments to IRS Urging Caution in Applying Cloud Transaction Framework to REIT Rules

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On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more

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

Morrison & Foerster LLP

Frequently Asked Questions about UPREITs and OP Unit Transactions

A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more

Greenberg Glusker LLP

IRS Extends Deadline for 1031 Exchanges Affected by the 2025 Southern California Wildfires: Key Points You Need to Know

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As a result of the wildfires and straight-line winds that began in Southern California on January 7, 2025, the IRS issued an extension of the 45- and 180-day deadlines for IRC §1031 exchange transactions....more

Williams Mullen

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

Williams Mullen on

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

DarrowEverett LLP

Maximizing Value: The Art of Purchase Price Allocation in Real Estate Deals

DarrowEverett LLP on

When a business is sold, the most important overall aspect of negotiations between a cautious buyer and determined seller may be due to the agreed-upon purchase price for the business. However, when the buyer is purchasing...more

Verrill

2023 Massachusetts Tax Update

Verrill on

Massachusetts Estate Tax: For decedents dying on or after January 1, 2023, there is no Massachusetts estate tax for an estate under $2,000,000. The law does not adjust the filing threshold so state tax returns may still be...more

Greenberg Glusker LLP

Los Angeles "Mansion Tax" - Measure ULA, Its Impact on Property Owners, & Refunds

Greenberg Glusker LLP on

In November 2022, Measure ULA, commonly known as the "Mansion Tax," was passed into law by the City of Los Angeles voters. This tax applies to all categories of real estate, including commercial, industrial, and residential...more

Freeman Law

Tax Court in Brief | Musselwhite v. Commissioner | Loss in Sale of Real Estate: Ordinary Loss or Capital Loss?

Freeman Law on

Tax Litigation:  The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Spencer v Commissioner, T.C....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

Jones Day

IRS Targeting Noncompliant Qualified Opportunity Funds and Their Investors

Jones Day on

On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more

Quarles & Brady LLP

IRS to Issue Opportunity Zone Compliance Letters

Quarles & Brady LLP on

On April 12, 2022, the Internal Revenue Service announced that taxpayers participating in the Qualified Opportunity Zone program who need to take additional actions would receive notice letters later in April. This...more

Sullivan & Worcester

Proposed Bipartisan Amendments to the Opportunity Zone Statute Could Have a Significant Effect on Current and Potential Investors

Sullivan & Worcester on

Late last week, a bipartisan group of U.S. Senators and U.S. Representatives introduced an expansive bicameral bill, titled the Opportunity Zones Transparency, Extension, and Improvement Act (the “OZ Bill”). This proposed...more

Freeman Law

What is a REIT? Real Estate Investment Trusts and Taxation

Freeman Law on

REITs, or real estate investment trusts, are often described as a mutual fund for real estate.  Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...more

McDermott Will & Schulte

The Working Capital Safe Harbor

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

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

Sullivan & Worcester

2020 Census Results Have No Impact on Boundaries of Opportunity Zones

Sullivan & Worcester on

The IRS has issued Announcement 2021-10 (the “Announcement”) in response to public questions regarding the potential effect the 2020 Census results may have on the boundaries of previously designated Opportunity Zones. ...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 Extends Relief for Qualified Opportunity Funds

Stinson LLP on

On January 19, 2021, the IRS issued Notice 2021-10, further extending relief for qualified opportunity funds (QOF) and their investors due to the COVID-19 pandemic. The IRS had provided relief last year in Notice 2020-39, and...more

Morgan Lewis

IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors

Morgan Lewis on

The Internal Revenue Service (IRS) issued Notice 2021-10 on January 19, which extends relief to Qualified Opportunity Funds (QOFs) and their investors as a response to continued challenges brought on by the COVID-19 pandemic....more

Lowndes

IRS Extends Much-Needed Opportunity Zone Relief

Lowndes on

This week, the IRS issued Notice 2021-10, which extends the June 4, 2020 relief that the IRS previously granted to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19...more

Hogan Lovells

Election 2020 Snapshot: Helping our real estate clients make sense of the U.S. election results

Hogan Lovells on

While there is an anticipation of greater predictability under a President Joe Biden, which is critically important to the commercial real estate industry, expected and potential changes in trade, taxation, housing and health...more

Ruder Ware

Responding to the Pandemic, IRS Loosens Opportunity Zone Requirements

Ruder Ware on

The IRS recently offered relief to Qualified Opportunity Fund investors, waiving a penalty and pushing back some investment deadlines. This new guidance comes as investment in opportunity zones slows, stymied by brisk...more

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