Category Archives: Tax Planning

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California Locally Assessed Property Tax: 2018 Appeal Filing Deadline Approaching

County Assessors across California believe that the property located in their counties is worth substantially more this year than it was last year. Each Assessor is required to prepare an annual assessment roll consisting of all taxable property in their county. In many counties, roll values increased substantially: San Francisco (↑10.80 percent), San Mateo (↑8.03 … Continue Reading

Limitations for Charitable Deductions and SALT Credits

The Tax Cuts and Jobs Act (TCJA) placed a $10,000 annual limit on the deductibility of state and local taxes (SALT). In response to and attempting to work around that limitation, several states enacted programs that create charitable entities, contributions to which would entitle the donor to a credit reducing their property tax. This would … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for September 2018 – Trending Up Again

The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month … Continue Reading

GT Alert – Highlights of the Tax Cuts and Jobs Act

On Dec. 20, 2017, the House and Senate passed the Tax Cuts and Jobs Act, H.R.1, and this bill is on its way to President Trump for signature.  When signed into law, the Tax Cuts and Jobs Act would have a wide impact on various aspects of U.S. federal individual, corporate, partnership, international, and trust and … Continue Reading

Tax Reform: The Impact on Tax-Exempt Bonds and Low-Income Housing Finance

The Senate Proposal – Some Good News. The Senate Finance Committee released its proposed tax bill (the “2017 Senate Tax Bill”) late on November 9, 2017. Unlike the 2017 House Tax Bill (defined below), the 2017 Senate Tax Bill would maintain current private activity bond provisions without modification (although, like the 2017 House Tax Bill, … Continue Reading

Making the Move to Another State? Consider These Actions to Avoid Dual State Residency

Whether to be closer to family member or a new job opportunity, individuals are increasingly relocating to another state.  If reduction in the applicable state income tax is a motivating reason, avoiding dual-residency should be a primary objective.  It is very common for owners of certain assets (closely-held businesses, highly-appreciated assets, and/or highly compensated executives … Continue Reading

California Court of Appeal Holds Passive LLC Interest Does Not Create Nexus

A non-California corporation’s only connection with California was its passive minority interest in a limited liability company (LLC) that was doing business in California. The California Court of Appeal held that this limited connection was not sufficient to subject the out of state corporation to California’s Corporation Franchise Tax. All taxpayers that have filed and … Continue Reading

Jon Forster and Scott Meza Participated in the GT co-hosted Presentation ‘Preparing For An Exit: What CEOs and CFOs Need to Know (and Do)’

Northern Virginia Greenberg Traurig Shareholders, Jon Forster and Scott Meza, participated as panelists in the program titled, “Preparing For An Exit: What CEOs and CFOs Need to Know (and Do)” on Nov. 2, 2016, in McLean, VA. Greenberg Traurig was a co-sponsor of this program. The program focused on specific elements of a successful M&A … Continue Reading

Treasury Department Issues Proposed Regulations That Will Dramatically Reduce Valuation Discounts

On Aug. 2, 2016, the Treasury Department issued proposed regulations under Section 2704 of the Internal Revenue Code that, if finalized in their present form, would substantially alter the valuation of transfers of interests in family-controlled entities (including corporations, partnerships, and LLCs) for estate, gift and generation-skipping transfer tax purposes. To read the full GT … Continue Reading

Portability of the Estate and Gift Tax Exclusion – How Does it Work?

Portability refers to the ability of a surviving spouse, to make use of a deceased spouse’s unused estate tax exclusion amount (DSUE amount).  Portability was intended to simplify estate planning for married couples by eliminating the need for a bypass trust.  However, in order to preserve the DSUE amount the surviving spouse must comply with … Continue Reading

Bill to Bar Air Excise Tax on Aircraft Management Fees Clears House Ways and Means Committee

A bill that would exempt aircraft management fees from the federal air transportation excise tax is advancing in the House — good news for aircraft owners who use a leasing company structure to save on state sales tax when purchasing aircraft. The bill (H.R. 3608) clarifies that fees paid to an aircraft services company to … Continue Reading

IRS Says Aircraft Leasing Entity is Eligible for 1031 Tax Free Exchange Treatment Despite Leasing to Related Companies at No Profit

We previously wrote about how a recently passed Texas bill (S.B. 1396) will allow certain in-state aircraft purchases to qualify for a resale exemption from sales tax, with the tax instead applied to later leasing contract payments. Now, a new IRS Chief Counsel memo says that an aircraft leasing partnership that trades in an aircraft that … Continue Reading
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