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Death, Taxes and Politics: The Future of Tax Policy Ahead of the 2024 Election
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#WorkforceWednesday: SCOTUS in Review, Biden Acts to Limit Non-Competes, NY HERO Act Model Safety Plans - Employment Law This Week®
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2020 Presidential Candidates' Tax Proposals
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Qualified Opportunity Zone Fund Investments
Investment Management Update – Exit Strategies
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Taking Advantage of Opportunity Zones: A Panel Discussion
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Life Sciences Quarterly: Tax Cuts and Jobs Act: Implications for Life Science Business
The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more
The 2017 Tax Cuts and Jobs Act generally limits the amount of business interest expense that a taxpayer may deduct. This webinar will cover newly issued final and proposed Treasury regulations under section 163(j), with a...more
In remarks at the NYU Tax Controversy Forum in June, the IRS discussed two new IRS return examination campaigns. Ms. Tamera Ripperda, the commissioner of the Tax Exempt and Government Entities (TEGE) Division who previously...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more
On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more
OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more
Last week, Treasury issued a second round of proposed regulations regarding Opportunity Zones?offering investors more clarity as to whether their investments in designated Opportunity Zones will qualify for current capital...more
While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more
On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly...more
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
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more
The Opportunity Zones Program created by the U.S. Tax Cut and Jobs Act of 2017 (the "OZone Program") and the first wave of proposed regulations issued by the Treasury Department on October 19, 2018 (the "Regulations") have...more
On October 19, the Treasury Department released a first round of guidance bringing much needed clarity to certain aspects of the Qualified Opportunity Fund regime enacted by the Tax Cuts and Jobs Act. While important...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
Due to the significant changes to the Internal Revenue Code (“Code”) made by the Tax Cuts and Jobs Act (“Tax Act”) at the end of last year, the Department of the Treasury has been very busy issuing guidance and proposed...more
On August 8th, the IRS released its much-awaited Proposed Regulations on the new Section 199A 20% profit deduction for pass-through businesses. The new deduction applies to essentially all types of businesses other than C...more
The Internal Revenue Service yesterday issued its much-anticipated Proposed Regulations on the new Section 199A 20% deduction for owners of pass-through business entities. This important deduction was created under the 2017...more
The Service issued proposed regulations corresponding to IRC § 199A yesterday. As discussed in a prior blog post, IRC § 199A potentially allows individuals, trusts and estates to deduct up to 20% of qualified business income...more
The U.S. tax act enacted in December 2017 includes a number of provisions that impact high net worth families with U.S. connections. For families with U.S. members, changes to the estate, gift and generation-skipping transfer...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
One of the most publicized changes made by last year’s Tax Cut and Jobs Act was a reduction in income tax rates for corporations and individuals. The maximum corporate tax rate has been permanently reduced from 35% to 21%,...more
“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