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Charitable Split-Interest Trust Planning With Dale Schroeder and Anneke Niemira - Part One
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On August 15, the Treasury Department published long-awaited guidance on applicability of “beginning of construction” safe harbors for solar and wind projects under the One Big Beautiful Bill and Executive Order 14315. While...more
In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more
This edition of the Private Company Report highlights critical updates and regulatory changes affecting private companies, including the expansion of Qualified Small Business Stock tax benefits under the One Big Beautiful...more
On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...more
Join our seasoned tax and estate planning attorneys on Wednesday, May 17th in Norfolk for the Williams Mullen Spring Tax Forum. Breakfast will be provided. This program will dig into complex private equity structures, how...more
The House and Senate are moving forward on several versions of legislation, which are collectively known as the “Secure Act 2.0” because they would build off of the Secure Act, the last major retirement plan legislation...more
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
If you are planning to acquire or build a senior living facility that is located in an opportunity zone, there are many tax benefits that are available to you. One of these benefits is that 10% of the capital gains that you...more
As we discussed in a previous article, the renewable energy industry is experiencing record growth. President Biden’s current initiatives are also expected to provide an additional boost to accelerate future growth in clean...more
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
On January 19, 2021, the IRS published guidance in Notice 2021-10, extending critical deadlines and rules relating to investments in qualified opportunity zones. First, any investors facing a deadline between April 1, 2020,...more
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
Notice 2020-86 (Notice) from the Internal Revenue Service (IRS) provides guidance to help interpret and apply certain Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) provisions that impact...more
The IRS recently published Notice 2020-86 (the “Notice”), which provides clarification with respect to certain changes made by the Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). In...more
On 4/15/20, the SBA and the U.S. Department of the Treasury released an application form for Paycheck Protection Program (PPP) loan forgiveness along with instructions for completing the form. ...more
Background - As the COVID-19 pandemic continues to disrupt project development timelines generally, solar and wind projects that rely on federal income tax credits to obtain financing are particularly sensitive to...more
On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more
On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more
Temporary Rules Keep Rolling in - The Oregon Department of Revenue (the “Department”) recently issued four new temporary rules relative to the Oregon Corporate Activity Tax (the “CAT”). The new rules went into effect on...more
Further clarity could help unlock much needed investment for a significant number of delayed projects. - After a two-year delay, the IRS finally issues highly anticipated guidance regarding the carbon capture tax credit...more
The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more
On December 20, 2019, the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) was signed into law. The SECURE Act is one of the most significant pieces of legislation impacting retirement plans in...more
Ever since defined contribution plans have come to dominate the retirement plan landscape, both plan sponsors and policymakers have grappled with how to help employees take a lifetime’s worth of savings and convert it into a...more
The guidance issued on February 19 by the Internal Revenue Service is the type that the carbon capture and storage industry had sought, and will hopefully open up the market for investment by eliminating tax-related...more