Tag Archive: "IRS"
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Tax Hedging in a Volatile Interest Rate Environment
Real estate companies often add significant debt loads to their balance sheets when acquiring rental properties. In a rising interest rate environment, a real estate company’s profit margins can quickly erode if the company has issued floating rate debt. Conversely, in a declining interest rate environment, a real estate company could suffer adverse P&L consequences […]
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Intersection of Current Tax Legislation and Opportunity Zones?
Opportunity zone legislation has been proposed several times over the past two years, but the current political uncertainty makes its future uncertain.
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The New (and Improved?) IRS Form 8308
Partnerships are required to file IRS Form 8308, Report of a Sale or Exchange of Certain Partnership Interests, to report the sale or exchange by a partner of all or part of a partnership interest where any money or other property received in exchange for the interest is attributable to unrealized receivables or inventory items. […]
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Planning for Deferred Tax Liabilities on Opportunity Zone Investments
Opportunity zone investors are schedule to recognize significant tax liabilities on deferred gains invested into qualified opportunity funds. Determining strategies to manage or minimize these taxes is a critical action in the OZ toolkit.
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IRS Takes Aim: Sweeping New Compliance Efforts Announced
The IRS recently announced the start of a “sweeping, historic” effort to restore fairness to the tax system, made possible by funding from the Inflation Reduction Act (“IRA”). Their plan to restore fairness in tax compliance focuses on shifting more attention to high-income earners, partnerships, large corporations, and promoter’s abusing our nation’s tax laws. The […]
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A Nice Surprise for California Taxpayers and Practitioners on October 16th
Today, the Internal Revenue Service (IRS) further postponed tax deadlines for most California taxpayers (55 of California’s 58 counties, all except Lassen, Modoc and Shasta counties, qualify) from October 16, 2023 to November 16, 2023. While the State of California generally conforms to disaster relief extensions announced by the IRS, final confirmation from the Franchise […]
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Disaster Relief for Opportunity Zone Taxpayers in the Southeast
New disaster area declarations provide relief to some opportunity zone taxpayers at a crucial time.
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Deficit Restoration Obligations in Partnership Agreements
In last week’s blog post, we shared two concepts that are essential to understanding partnership allocations under Internal Revenue Code (IRC) Section 704. While last week’s blog post focused on the role of Substantial Economic Effect in partnership agreements, today’s blog post will stress the importance of Deficit Restoration Obligations (DROs) in partnership agreements. DROs […]
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Understanding Substantial Economic Effect in Partnership Agreements
Partnerships provide a valuable framework for collaboration in business, but navigating the tax implications of partnership agreements can be complex. One critical, yet often overlooked concept, is the determination of a partner’s distributive share of allocable partnership items, which is covered under Internal Revenue Code (IRC) Section 704. Under IRC Section 704(b), if a partnership […]
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New Opportunity Zone Legislation Introduced
Congress introduces new OZ legislation to expand the program to rural census tracts and increase transparency through added informational reporting.