Airport Concessionaire’s Exclusive Operating Right is Tax-Exempt Intangible Asset, and Assessor Had Burden of Removing Value of Asset in Making Property Tax Assessment

Posted in GT Alert, State Tax

This GT Alert addresses the recent Court of Appeal decision in DFS Group LP v. County of San Mateo (Calif. Ct. App., 1st Dist., January 31, 2019, 31 Cal.App.5th 1059; Petition for Review denied by Calif. Supreme Ct., April 24, 2019), which held that local assessors and assessment appeals boards must address intangible assets in their assessment of property for property tax purposes, including intangibles relating to exclusive operating rights at an international airport.

Intangible assets are exempt from property tax assessment in California. The exemption extends to cash, government permits, intellectual property, assembled workforce, working capital, favorable contracts, naming rights, training and instruction manuals and, in DFS Group, an exclusive concession to operate a business on government-owned property. In short, California assessors can assess the real property on which a business is located, and the personal property used by the business, but cannot assess “business enterprise” or other intangible assets.

To read the full GT Alert, click here.

For more on SALT, click here.

In the Zone: GT Qualified Opportunity Zone News – June 2019

Posted in Opportunity Zones, qualified opportunity funds, qualified opportunity zones, Real Estate, real estate tax, Uncategorized

Welcome to In the Zone: GT Qualified Opportunity Zone News. Our monthly digest of the latest federal and state developments in Qualified Opportunity Zones and Qualified Opportunity Funds and related Greenberg Traurig news and events will keep stakeholders apprised of the most pressing issues in this burgeoning space.

AROUND D.C.:

DCA Live Qualified Opportunity Zone Event

GT Client Kyle Walker (Principal, CEO NewGen Worldwide) (pictured, left), and Robert Maples (GT NVA) (pictured, right) attended a DCA Live Qualified Opportunity Zone event featuring Scott Turner (pictured, middle), executive director of the White House Opportunity and Revitalization Council. Mr. Turner spoke to the White House’s commitment to the dual missions of opportunity zones; economic improvement and social change. Mr. Turner was accompanied by Alfonso Costa, agency lead on Opportunity Zones, Department of Housing and Urban Development.

IN CONGRESS:

Reps. Ron Kind (D-WI)  and Mike Kelly (R-PA) Introduce Bill to Add Transparency to Opportunity Zones Program.  Companion legislation was introduced in the Senate by Sens. Cory Booker (D-NJ), Tim Scott (R-SC), Maggie Hassan (D-NH) and Todd Young (R-IN).

Read the bill here.

IN LOCAL NEWS:

“How Opportunity Zones Are Working in North Miami. The question for municipalities is how to get your town to the top of the heap for Opportunity Zones.”

The article states:

“A study by the Center for Real Estate and Urban Analysis by the George Washington University suggested this set of policies to leverage the capital investment from Opportunity Zones:

  1. Instituting “do no harm” policies that protect vulnerable populations and existing businesses.
  2. Developing a comprehensive investable project pipeline that creates long-term housing and transportation affordability while accelerating job creation.
  3. Instituting an inclusive community engagement process for determining projects and initiatives.
  4. Planning for a mix of housing affordable to the workforce you expect in the neighborhood.
  5. Updating zoning codes to facilitate a mix of uses.
  6. Encouraging development near transit, particularly projects that help meet community goals, such as affordable housing.
  7. Inventorying properties that are ripe for redevelopment. For each property, compile information about condition, ownership, tax status, liens, zoning, and any other information that a new owner might need to understand costs of acquisition.
  8. Prioritizing access within the area instead of mobility through it.”

Opportunity Zones: Here’s where Orlando businesses can benefit,Orlando Business Journal, June 3, 2019 (registration required) – Below are a few quotes from GT Shareholder James Lang:

“Orlando…has some fantastic business opportunities going on right now, both in the real estate and operating business side, both of which are affected by qualified Opportunity Zone investments.”

“The city of Orlando…has created prospectuses for the Opportunity Zones and has branded the specific areas that are Opportunity Zones. It is taking a proactive approach and a leading role so the communities retain the character the city encourages today, while also encouraging revitalization that the law intended to bring into these communities.”

UPCOMING SPEAKING ENGAGEMENTS:

July 9, 8:00 a.m. – 9:30 a.m, Tampa.: Opportunity Fund Presentation for accountants Cohen & Grieb, PA

Aug. 15, 7:30 a.m. – 9:30 a.m., Tampa: Qualified Opportunity Zone and Hillsborough County Economic Development Programs for Uptown Tampa

  • Tampa Innovation Partnership is hosting a Real Estate Breakfast to discuss development incentives in the area including the Qualified Opportunity Zone and Hillsborough County economic development programs. GT Shareholder James Lang will provide an introduction to the Qualified Opportunity Zone and QOZ Funds. Much of the Uptown area lies within designated Opportunity Zones and the potential for the program to attract private investment could be transformative for the area. Eric Lindstrom, competitive sites and redevelopment manager for the Hillsborough County Economic Development Department, will share details about incentives and opportunities from the county that can be beneficial to developers and businesses.

Sept. 19, 8:30 a.m. – 9:30 a.m – Philadelphia.: Greenberg Traurig is pleased to host ULI NEXT for an engaging presentation on Philadelphia Opportunity Zones. GT

  • Shareholder James O. Lang will present highlights and insights on the latest regulation and guidance for this new incentive for real estate and operating business investment in targeted areas, Qualified Opportunity Zones.

PAST EVENTS:

June 5: NAIOP Tampa Bay Opportunity Zone Extended Lunch Event. Jim Lang was a featured speaker (pictured at the podium below).

June 20: Qualified Opportunity Zones: New Tax Incentives for Commercial Real Estate and Other Investment, Strafford Webinar, Jim Lang Presenter

June 18: Society of Real Estate Professionals Breakfast, “Less Talk, More Action: Breaking Ground on Opportunity Zones”

June 19: GT Orlando hosted the Indian American Chamber of Commerce for an Opportunity Zones Discussion with Jim Lang

Contact Sharon Mangione with any questions.

Visit GT’s Opportunity Zone Funds page for practice details.

Applicable Federal Rates and Code Section 7520 Rate for July 2019 – Downward Trend Continues

Posted in Applicable Federal Rates (AFRs)

The Internal Revenue Service (IRS) publishes the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the AFRs and 7520 rate for the following month provides a window of opportunity for the immediate or delayed implementation of income, gift, and estate-tax planning techniques in response to upward or downward trends. Effective implementation and management of interest-sensitive estate planning techniques involves numerous other factors in addition to the relevant AFR or the 7520 rate, including a client’s particular personal and financial circumstances and should be undertaken only with the advice of competent tax counsel and financial advisers.

The IRS has issued Revenue Ruling 2019-16, which provides the AFRs and 7520 rate for July 2019. Revenue Ruling 2019-16 will appear in Internal Revenue Bulletin 2019-28 dated July 8, 2019. The downward trend that began in January 2019 continues, with all AFRs and 7520 rate below 2.5% in July 2019.

What is the Applicable AFR? The applicable AFR is the minimum safe-harbor interest rate that must apply to loans between related parties (intra-family loans) to avoid adverse income or gift-tax consequences — based on the month in which the loan is made, how frequently interest is compounded, and the length (term) of the loan.

AFRs Trending Down. AFRs have decreased across the board from June 2019 levels, making intra-family loans and installment sales to grantor trusts generally more attractive.

July 2019 AFRs Summary. The AFRs for July 2019 are as follows:

AFR ANNUAL SEMI-ANNUAL QUARTERLY MONTHLY
Short-Term 2.13% 2.12% 2.11% 2.11%
Mid-Term 2.08% 2.07% 2.06% 2.06%
Long-Term 2.50% 2.48% 2.47% 2.47%

Historical AFRs. The AFRs for July 2018 through July 2019 are as follows, in reverse chronological order:

AFR ANNUAL SEMI-ANNUAL QUARTERLY MONTHLY
Short-Term AFRs – For demand notes and notes with a term of three years or less.
July 2019 2.13% 2.12% 2.11% 2.11%
June 2019 2.37% 2.36% 2.35% 2.35%
May 2019 2.39% 2.38% 2.37% 2.37%
April 2019 2.52% 2.50% 2.49% 2.49%
March 2019 2.55% 2.53% 2.52% 2.52%
February 2019 2.57% 2.55% 2.54% 2.54%
January 2019 2.72% 2.70% 2.69% 2.68%
December 2018 2.76% 2.74% 2.73% 2.72%
November 2018 2.70% 2.68% 2.67% 2.67%
October 2018 2.55% 2.53% 2.52% 2.52%
September 2018 2.51% 2.49% 2.48% 2.48%
August 2018 2.42% 2.41% 2.40% 2.40%
July 2018 2.38% 2.37% 2.36% 2.36%
Mid-Term AFRs – For notes with a term in excess of three years but no greater than nine years.
July 2019 2.08% 2.07% 2.06% 2.06%
June 2019 2.38% 2.37% 2.36% 2.36%
May 2019 2.37% 2.36% 2.35% 2.35%
April 2019 2.55% 2.53% 2.52% 2.52%
March 2019 2.59% 2.57% 2.56% 2.56%
February 2019 2.63% 2.61% 2.60% 2.60%
January 2019 2.89% 2.87% 2.86% 2.85%
December 2018 3.07% 3.05% 3.04% 3.03%
November 2018 3.04% 3.02% 3.01% 3.00%
October 2018 2.83% 2.81% 2.80% 2.79%
September 2018 2.86% 2.84% 2.83% 2.82%
August 2018 2.80% 2.78% 2.77% 2.76%
July 2018 2.87% 2.85% 2.84% 2.83%
Long-Term AFRs – For notes with a term in excess of nine years.
July 2019 2.50% 2.48% 2.47% 2.47%
June 2019 2.76% 2.74% 2.73% 2.72%
May 2019 2.74% 2.72% 2.71% 2.70%
April 2019 2.89% 2.87% 2.86% 2.85%
March 2019 2.91% 2.89% 2.88% 2.87%
February 2019 2.91% 2.89% 2.88% 2.87%
January 2019 3.15% 3.13% 3.12% 3.11%
December 2018 3.31% 3.28% 3.27% 3.26%
November 2018 3.22% 3.19% 3.18% 3.17%
October 2018 2.99% 2.97% 2.96% 2.95%
September 2018 3.02% 3.00% 2.99% 2.98%
August 2018 2.95% 2.93% 2.92% 2.91%
July 2018 3.06% 3.04% 3.03% 3.02%

Note that the “blended annual rate” under Code Section 7872(e)(2)(A) may be used to determine the interest on a demand loan (i.e., a loan which can be called in at any time) with a fixed principal amount outstanding for an entire year.

What is the 7520 Rate? The 7520 rate for the month in which a lifetime gift or testamentary transfer occurs is used to determine the gift- or estate-tax value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest. In the case of a charitable life estate or remainder, however, the 7520 rate for the month in which the lifetime gift or testamentary transfer occurs or a rate for either of the two preceding months may be used to determine its income-, gift-, or estate-tax value. The 7520 rate is equal to 120% of the applicable mid-term rate using semi-annual compounding, adjusting the resulting rate to produce an equivalent yield for annual compounding, and then rounding it to the nearest two-tenths of a percent.

7520 Rate Trending Down. The 7520 rate also has continued its downward trend, making planning techniques like grantor retained annuity trusts (GRATs) and charitable lead annuity trusts (CLATs) more attractive. Conversely, qualified personal residence trusts (QPRTs) and charitable remainder annuity trusts (CRATs) have become less attractive.

7520 Rate for July 2019. The 7520 rate for July 2019 is 2.6%, down from 2.8% for May and June 2019.

Historical 7520 Rates. The 7520 rates for July 2018 through July 2019 are as follows, in reverse chronological order:

7520 RATE
July 2019 2.60%
June 2019 2.80%
May 2019 2.80%
April 2019 3.00%
March 2019 3.20%
February 2019 3.20%
January 2019 3.40%
December 2018 3.60%
November 2018 3.60%
October 2018 3.40%
September 2018 3.40%
August 2018 3.40%
July 2018 3.40%

For more on AFRs, click here.

Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

Posted in GT Alert, Internal Revenue Code, International Tax, IRS, tax audits, tax withholding

Campaign for Compliance

Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who make payments of certain U.S.-source income to foreign persons must comply with withholding, deposit, and reporting requirements. The IRS campaign promised to address “withholding agents who make such payments but do not meet all their compliance duties.”

In accordance with this promise, the IRS initiated the campaign, uncovering several thousand noncompliant withholding agents for the 2017 tax year alone. Letters addressing this noncompliance are now being sent to withholding agents on an “ongoing, rolling basis,” according to Kimberly Schoebacher, IRS Acting Director for Foreign Payments of the Large Business and International Division.

For those with tax withholding and Forms 1042 and 1042-S reporting requirements, now is the time to come forward and voluntarily disclose previous noncompliance to try to avoid penalties. Schoebacher stated that once a campaign letter is received, penalty abatement is unavailable.

Click here for the full GT Alert, which explores the procedures for disclosure, pitfalls for the unwary, and why the time is now to take advantage of the disclosure procedures to correct any noncompliance. 

Proposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property Interests

Posted in foreign investment tax, GT Alert, Internal Revenue Code, Investing, IRS, Real Estate, real estate tax

The Foreign Investment in Real Property Tax Act of 1980, as amended (FIRPTA), imposes tax on gain realized on disposition by nonresident alien individuals or foreign corporations (non-U.S. persons) of a U.S. real property interests (USRPI) by treating such gain as effectively connected with the conduct of a U.S. trade or business by such non-U.S. persons (effectively connected income, or ECI). The FIRPTA tax is enforced by requiring the purchaser (or other transferees) of a USRPI from a foreign person to withhold an applicable percentage (generally 15%) of the gross proceeds and pay over to the Internal Revenue Service (IRS). On June 7, 2019, the IRS and the Treasury Department issued proposed regulations (the Proposed Regulations) on Section 897(l) of the Internal Revenue Code (the Code) that provides an exemption from the FIRPTA tax for qualified foreign pension funds (QFPF) on gains or losses attributable to dispositions of USRPI. The Proposed Regulations provide rules for determining the qualification for the exemption under Section 897(l), including certain organizational structures that are eligible for such exemption. The Proposed Regulations also clarify certification and documentation requirements with respect to withholding obligations under Sections 1445 and 1446. In addition, the Proposed Regulations provide certain anti-avoidance rules by imposing conditions on the sale of certain investment vehicles wholly owned by a QFPF.

Click here to read the full GT Alert.

Greenberg Traurig’s Jim Lang Speaks at NAIOP Tampa Bay – Oppportunity Zone Extended Lunch Event

Posted in Event, Opportunity Zones

Greenberg Traurig Shareholder Jim Lang was a speaker at NAIOP Tampa Bay’s Opportunity Zone Lunch. The presentation highlighted how businesses can identify and structure benefits under the Qualified Opportunity Zone incentive.

Click here for information on Greenberg Traurig’s Opportunity Zone Funds Practice.

IRS Says Special Program Bonds Including Tribal Development Bonds May Be Current Refunded

Posted in GT Alert, Internal Revenue Code, IRS, Tax Planning

While the advance refunding of tax-advantaged bonds remains a thing of the past, the Internal Revenue Service (IRS) issued guidance on May 22, Notice 2019-39, expanding the realm of current refundings to permit the current refunding of all existing and future tax-exempt bond programs that impose bond volume cap, issuance time deadlines, or both, for which the statute under which such programs operate does not address the permissibility of current refunding bonds.

Background

Over the years, Congress has enacted several targeted tax-exempt bond programs, often to provide disaster relief or promote economic development in underserved areas. Such bonds include “GO Zone Bonds” under former Section 1400N of the Internal Revenue Code of 1986, as amended (the Code), Midwest Disaster and Hurricane Ike Disaster Bonds under Code Sections 702(d)(1) and 704(a) of the Heartland Disaster Relief Act, Recovery Zone Facility Bonds under former Code Section 1400U-3, and Tribal Economic Development Bonds issued under Code Section 7871(f).

Unlike other tax-advantaged bonds, these targeted programs were authorized under statutory provisions that did not address whether an issuer could current refund such bonds. The Treasury and IRS have addressed on a piecemeal basis the ability to current refund certain of these programs. See, e.g., Notice 2012-3, 2012-3 I.R.B. 289 (GO Zone, Midwest, and Hurricane Ike Disaster Bonds); Notice 2014-39, 2014-5 I.R.B. 455 (Recovery Zone Facility Bonds); and Notice 2003-40, 2003-2 C.B. 20 (New York Liberty Bonds).

Click here to read the full GT Alert.

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. Shareholders

Posted in Code Section 956, controlled foreign corporation, GT Alert, Internal Revenue Code, IRS

On May 23, 2019, the Internal Revenue Service (IRS) and the Treasury Department issued final regulations (the Final Section 956 Regulations) intended to mitigate the impact of Section 956 of the Internal Revenue Code (the Code) for certain domestic corporations. Consistent with the proposed regulations issued in November 2018 (see previous GT Alert here), the Final Section 956 Regulations align the application of the deemed income received under Section 956 with the participation exemption created under Section 245A of the Code, enacted by the 2017 Tax Cuts and Jobs Act (P.L. 115-97).

Prior to enactment of Section 245A, both actual and Section 956-deemed dividends that arose due to certain investments in U.S. property were included in the income of a domestic corporation and taxed symmetrically. The enactment of Section 245A provides for a participation exemption regime pursuant to which a 100 percent dividends-received deduction (DRD) is available to a corporate U.S. shareholder with respect to dividends received from the untaxed earnings of a “specified 10-percent owned foreign corporation” that are actually distributed to the shareholder. A specified 10-percent owned foreign corporation is any foreign corporation (other than certain passive foreign investment companies) with respect to which a domestic corporation owns at least 10 percent of voting power or value. Thus, a specified 10-percent owned foreign corporation includes a controlled foreign corporation (CFC) with respect to its corporate U.S. 10 percent shareholders. Contrary to the provisions of Section 245A, a Section 956 inclusion of a corporate U.S. shareholder of a CFC was not eligible for the DRD, thus creating unequal treatment between actual and deemed repatriations.

Click here to read the full GT Alert.

Applicable Federal Rates and Code Section 7520 Rate for June 2019 – Downward Trend Slowing Down

Posted in Applicable Federal Rates (AFRs), Internal Revenue Code

The Internal Revenue Service (IRS) publishes the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for a particular month in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the AFRs and 7520 rate for the following month provides a window of opportunity for the quick or delayed implementation of income, gift, and estate-tax planning techniques in response to upward or downward trends. Effective implementation and management of interest-sensitive estate planning techniques involves numerous other factors in addition to the relevant AFR or 7520 rate, including a client’s particular personal and financial circumstances and should be undertaken only with the advice of competent tax counsel and financial advisers.

The IRS has issued Revenue Ruling 2019-14, which provides the AFRs and 7520 rate for June 2019. Revenue Ruling 2019-14 will appear in Internal Revenue Bulletin 2019-23 dated June 3, 2019. While the downward trend that began in January 2019 continues, with all AFRs and 7520 rate below 3% in June 2019, it is slowing down.

What is the Applicable AFR? The applicable AFR is the minimum safe-harbor interest rate that must apply to loans between related parties (intra-family loans) to avoid adverse income or gift-tax consequences – based on the month in which the loan is made, how frequently interest is compounded, and the length (term) of the loan.

AFRs Trending Down. AFRs have decreased since January 2019, making intra-family loans and installment sales to grantor trusts generally more attractive. While the June 2019 short-term AFRs have decreased vis-à-vis the AFRs for May 2019, the June 2019 mid- and long-term AFRs have inched up slightly since May 2019.

June 2019 AFRs Summary. The AFRs for June 2019 are as follows:

AFR ANNUAL SEMI-ANNUAL QUARTERLY MONTHLY
Short-Term 2.37% 2.36% 2.35% 2.35%
Mid-Term 2.38% 2.37% 2.36% 2.36%
Long-Term 2.76% 2.74% 2.73% 2.72%

Historical AFRs. The AFRs for June 2018 through June 2019 are as follows, in reverse chronological order:

AFR ANNUAL SEMI-ANNUAL QUARTERLY MONTHLY
Short-Term AFRs – For demand notes and notes with a term of three years or less.
June 2019 2.37% 2.36% 2.35% 2.35%
May 2019 2.39% 2.38% 2.37% 2.37%
April 2019 2.52% 2.50% 2.49% 2.49%
March 2019 2.55% 2.53% 2.52% 2.52%
February 2019 2.57% 2.55% 2.54% 2.54%
January 2019 2.72% 2.70% 2.69% 2.68%
December 2018 2.76% 2.74% 2.73% 2.72%
November 2018 2.70% 2.68% 2.67% 2.67%
October 2018 2.55% 2.53% 2.52% 2.52%
September 2018 2.51% 2.49% 2.48% 2.48%
August 2018 2.42% 2.41% 2.40% 2.40%
July 2018 2.38% 2.37% 2.36% 2.36%
June 2018 2.34% 2.33% 2.32% 2.32%
Mid-Term AFRs – For notes with a term in excess of three years but no greater than nine years.
June 2019 2.38% 2.37% 2.36% 2.36%
May 2019 2.37% 2.36% 2.35% 2.35%
April 2019 2.55% 2.53% 2.52% 2.52%
March 2019 2.59% 2.57% 2.56% 2.56%
February 2019 2.63% 2.61% 2.60% 2.60%
January 2019 2.89% 2.87% 2.86% 2.85%
December 2018 3.07% 3.05% 3.04% 3.03%
November 2018 3.04% 3.02% 3.01% 3.00%
October 2018 2.83% 2.81% 2.80% 2.79%
September 2018 2.86% 2.84% 2.83% 2.82%
August 2018 2.80% 2.78% 2.77% 2.76%
July 2018 2.87% 2.85% 2.84% 2.83%
June 2018 2.86% 2.84% 2.83% 2.82%
Long-Term AFRs – For notes with a term in excess of nine years.
June 2019 2.76% 2.74% 2.73% 2.72%
May 2019 2.74% 2.72% 2.71% 2.70%
April 2019 2.89% 2.87% 2.86% 2.85%
March 2019 2.91% 2.89% 2.88% 2.87%
February 2019 2.91% 2.89% 2.88% 2.87%
January 2019 3.15% 3.13% 3.12% 3.11%
December 2018 3.31% 3.28% 3.27% 3.26%
November 2018 3.22% 3.19% 3.18% 3.17%
October 2018 2.99% 2.97% 2.96% 2.95%
September 2018 3.02% 3.00% 2.99% 2.98%
August 2018 2.95% 2.93% 2.92% 2.91%
July 2018 3.06% 3.04% 3.03% 3.02%
June 2018 3.05% 3.03% 3.02% 3.01%

Note that the “blended annual rate” under Code Section 7872(e)(2)(A) may be used to determine the interest on a demand loan (i.e., a loan which can be called in at any time) with a fixed principal amount outstanding for an entire year.

What is the 7520 Rate? The 7520 rate for the month in which a lifetime gift or testamentary transfer occurs is used to determine the gift- or estate-tax value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest. In the case of a charitable life estate or remainder, however, the 7520 rate for the month in which the lifetime gift or testamentary transfer occurs or a rate for either of the two preceding months may be used to determine its income-, gift-, or estate-tax value. The 7520 rate is equal to 120% of the applicable mid-term rate using semi-annual compounding, adjusting the resulting rate to produce an equivalent yield for annual compounding, and then rounding it to the nearest two-tenths of a percent.

7520 Rate Trending Down. The 7520 rate also has continued its downward trend, making planning techniques like grantor retained annuity trusts (GRATs) and charitable lead annuity trusts (CLATs) more attractive. Conversely, qualified personal residence trusts (QPRTs) and charitable remainder annuity trusts (CRATs) have become less attractive.

7520 Rate for June 2019. The 7520 rate for June 2019 remain the same as for May 2019, 2.8%.

Historical 7520 Rates. The 7520 rates for June 2018 through June 2019 are as follows, in reverse chronological order:

7520 RATE
June 2019 2.80%
May 2019 2.80%
April 2019 3.00%
March 2019 3.20%
February 2019 3.20%
January 2019 3.40%
December 2018 3.60%
November 2018 3.60%
October 2018 3.40%
September 2018 3.40%
August 2018 3.40%
July 2018 3.40%
June 2018 3.40%

For more on AFRs, click here.

Greenberg Traurig’s Cris O’Neall Recognized as ‘Tax Advocate of the Year’

Posted in awards

ORANGE COUNTY – May 21, 2019 – Cris K. O’Neall of global law firm Greenberg Traurig, LLP’s Orange County office has been recognized as “Tax Advocate of the Year” by the California Alliance of Taxpayer Advocates (CATA).

The recognition was based in part on O’Neall’s role in getting amendments to California’s Property Tax Rules approved by the California State Board of Equalization (SBE) in 2018. The process took many months and included written submissions to the SBE, meetings with SBE staff members, and hearings before elected SBE Members. The Property Tax Rule changes will assist taxpayers in responding to information requests from tax authorities and in making presentations before county Assessment Appeals Boards.

Click here to read the full press release.

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