Tag Archives: gt law

State and Local Tax Briefing: 2020 California State-Assessed Property Tax Assessment Appeals

The California State Board of Equalization (BOE) is responsible for assessing property tax on certain public utilities and other specified companies, including telephone companies and companies selling or transmitting gas or electricity, enabling counties to use those assessed values to collect local property taxes. These companies are commonly referred to as “state assessees” and their … Continue Reading

Section 501(c)(3) Organization Prohibited Political Activities

Political activities of charities and other types of exempt organizations frequently rise in prominence in presidential election years.  Not only is the IRS sensitive to political activities in a presidential election year, private organizations frequently monitor election activities of charities and may report to the IRS violations of the political activity prohibition.  Consequently, it is … Continue Reading

Uncertainty, COVID-19, and Estate Planning: A Unique Opportunity to Plan

The Coronavirus Disease 2019 (COVID-19) pandemic has created personal uncertainty for many due to living in quarantine and apart from extended family members, and financial stress due to market volatility and the unclear future for some businesses. Yet, it may be a sensible time to engage in estate planning, not only because the pandemic has … Continue Reading

Now That I Have My Paycheck Protection Program Money, What Can I Do with It?

Q. Assuming I properly received PPP funds, what can I spend it on?  A. The allowable uses of PPP loan funds are as follows: 75% of the PPP loan funds must be used for payroll costs for U.S. resident employees (salaries are capped at $100,000 per employee), The remaining 25% may be spent on: Costs … Continue Reading

IRS Provides Procedural Relief to Real Estate Businesses with Respect to Their Interest Deduction Limitation

Under the Tax Cuts and Jobs Act of 2017, the new Section 163(j) generally limits a taxpayer’s deduction of any business interest expense to 30% of the taxpayer’s adjusted taxable income (ATI) plus the taxpayer’s business interest income. However, certain real estate and farming businesses are permitted to make an irrevocable election to avoid the … Continue Reading

U.S. Federal Tax Changes in Response to Coronavirus Disease 2019

As part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that was passed on March 27, 2020, important tax-related provisions were enacted into law relating to individuals, corporations, businesses, retirement plans, and nonprofits. In addition, the Internal Revenue Service (IRS) has issued relief measures regarding filing tax returns, payment of federal taxes, … Continue Reading

Tax Credit for Emergency Sick Leave and Family Leave Paid by Employers Under the Families First Coronavirus Response Act

The Families First Coronavirus Response Act (FFCRA), which has been signed into law, requires companies that employ less than 500 employees to pay 80 hours of sick leave and up to 12 weeks of family leave for employees who are required to stay home because of six specific Coronavirus Disease 2019 (COVID-19)-related reasons. This March … Continue Reading

GT ALERT – States Revise 2019 Tax Filing Deadlines

The Internal Revenue Service (IRS) has extended the filing date for 2019 tax returns from April 15 to July 15.  Several states also have extended filing deadlines and payment due dates for 2019 tax returns because of the Coronavirus Disease 2019 (COVID-19) pandemic. To read the full alert, click here.… Continue Reading

GT ALERT – COVID-19’s Impact on California Property Tax Deadlines and Planning Considerations

The Coronavirus Disease 2019 (COVID-19) crisis has raised questions and concerns about upcoming property tax payment and reporting deadlines in California and whether taxpayers may be entitled to any relief due to a decline in property values. The discussion below addresses these issues. April 10 Property Tax Payment Deadline California state legislators, the state controller, … Continue Reading

AB 5, California’s Gig-Work Law, Could Mean Inconsistent Federal and State Tax Treatment for Workers

On Sept. 18, 2019, Governor Gavin Newsom signed Assembly Bill No. 5 (AB 5) into law in California. The landmark legislation, which came into effect Jan. 1, 2020, promises to significantly expand the number of workers treated as employees for state tax and labor purposes. Although the legislation was aimed at participants in the “gig … Continue Reading

Qualified Opportunity Zones – Final Treasury Regulations Released

On Dec. 19, the United States Department of the Treasury released final regulations related to investment in Qualified Opportunity Zones and Qualified Opportunity Funds (544 pages). These highly anticipated regulations and related guidance provide critical information to investors, Qualified Opportunity Funds (QOFs), and project sponsors/operators involved in real estate, venture capital, operating businesses, and project finance in Qualified Opportunity … Continue Reading

IRS Issues New Cryptocurrency Guidance

On Oct. 9, 2019, the Internal Revenue Service (IRS) released revenue ruling (Rev. Rul. 2019-24) and a Frequently Asked Questions (FAQs) document, which provide additional guidance on the tax treatment and reporting obligations for transactions involving virtual currency (also known as cryptocurrency). This guidance supplements the original guidance that was issued in 2014 in the … Continue Reading

Greenberg Traurig Sponsors 2019 Samsung Gives Charity Gala

Greenberg Traurig recently sponsored the 2019 Samsung Gives Charity Gala in New York City. With hundreds of guests in attendance, including musicians, athletes, and celebrities, this program is dedicated to celebrating worthy causes, furthering community impact, and honoring organizations and the people who work so hard every single day to make the world a better place. … Continue Reading

IRS Offers Settlements to Some Micro-Captive Insurance Taxpayers

On Sept. 16, 2019, the IRS announced it is offering settlements to certain taxpayers with open audits of micro-captive insurance transactions. The IRS has targeted these micro-captive insurance transactions since 2014, and they were designated as transactions of interest in 2016.1 Although micro-captive insurance transactions have gained popularity among closely held entities, the IRS has challenged such … Continue Reading

Retailers Not Eligible for 100% Leasehold Improvement Write-Off Due to Legislative Glitch

The 2017 Tax Cuts and Jobs Act provided a 100% first year write-off for many types of capital expenditures. Congressional tax writers intended this benefit to be available for leasehold improvements, which would be a boon to retail and restaurant businesses and their landlords. Unfortunately, in the rush to get the tax bill pushed through, … Continue Reading

IRS Aims to Catch Up to Tech Advancements

Recently proposed IRS regulations would significantly affect tax on income from international cloud transactions and electronic transfers of digital content. Accordingly, CFOs should review the structure of agreements involving such transactions and transfers. Issued on Aug. 9, the proposed regulations represent an attempt by the IRS to catch up with technological advancements, two decades after … Continue Reading

In the Zone: GT Qualified Opportunity Zone News – July and August 2019

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. President Trump’s Tweets Show Continued Strong Support … Continue Reading

IRS Clarifies U.S. Tax Treatment of Cross-Border Cloud and Other Online Transactions in Proposed Regulations

On Aug. 9, 2019, the IRS issued proposed regulations (Proposed Regulations) addressing the U.S. federal income tax treatment of cross-border cloud transactions. The Proposed Regulations will not become effective until final rules are adopted. By way of background, the last time the IRS meaningfully addressed the taxation of cross-border digital content transfers was in October … Continue Reading

Is the 2017 Tax Law the Reason Home Sales Are Not Booming?

Many blame rising home prices, construction and land costs, and a lack of inventory, but a large part of the reason for this disconnect between home sales and the economy may be due to changes in the 2017 Tax Cuts and Jobs Act (TCJA) that either reduced or eliminated the tax advantage of purchasing a … Continue Reading

2 Tax Updates from GT’s Blockchain & Cryptocurrency Newsletter – Spring/Summer 2019

IRS Warns Cryptocurrency Investors That They May Owe Tax Money The Internal Revenue Service announced on July 26 that it has begun sending letters to taxpayers with virtual currency (also known as cryptocurrency) transactions who potentially failed to report income on them and pay the resulting tax, and/or did not report their transactions properly. The … Continue Reading

Effect of Kaestner on Non-California Trusts With California Beneficiaries

On June 21, 2019, in a unanimous decision, the U.S. Supreme Court held as unconstitutional a North Carolina statute that had been interpreted by North Carolina to mean that a trust owed income tax to North Carolina whenever a beneficiary of the trust lived in the state, even if, in the relevant year, the beneficiary … Continue Reading

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

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 … Continue Reading
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