Tag Archives: gt_law

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

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. … Continue Reading

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

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.… Continue Reading

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

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 … Continue Reading

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

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 … Continue Reading

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

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 … Continue Reading

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

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 … Continue Reading

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

Welcome to the May 2019 issue of 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. In the Administration: … Continue Reading

Refundable State Tax Credits: Maybe Don’t Take the Money and Run

On April 25, 2019, the United States Court of Appeals for the Federal Circuit decided that refundable state tax brownfield credits are taxable income for federal purposes. The court held in Ginsburg v. United States, “The excess amount of the brownfield redevelopment tax credit received by the Ginsburgs in 2013 is taxable gross income because it … Continue Reading

GT Executive Summary & Detailed Analysis: IRS Issues Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations

Greenberg Traurig is pleased to provide our guidance on the Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations issued by the U.S. Treasury on April 17, 2019.     Here are the links to our two-part guidance: Part  I –  Executive Summary: IRS Issues Second Installment of Qualified Opportunity Zone Fund (QOF) Proposed Regulations … Continue Reading

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

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 … Continue Reading

In the Zone: GT Qualified Opportunity Zone News – April 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. At the White House  HOT DOCS– Treasury … Continue Reading

Highly Anticipated Qualified Opportunity Zone Proposed Treasury Regulations Released

On Wednesday, April 17, the United States Department of the Treasury released proposed regulations related to investment in Qualified Opportunity Zones and Qualified Opportunity Funds. The issuance of these highly anticipated regulations and related guidance will provide critical information to investors, Qualified Opportunity Funds, and project sponsors/operators involved in real estate, venture capital, operating business, … Continue Reading

Veterans Housing Preference Permitted Under IRC Section 42 Now Permitted Under 142

On April 3, 2019, the IRS released Revenue Procedure 2019-17, providing that the general public use requirement of section 142(d) of the Internal Revenue Code (relating to residential rental projects) permits the use of housing preferences and occupancy restrictions consistent with the provisions of the low-income housing tax credit requirements under section 42(g)(9) of the … Continue Reading

In the Zone: GT Qualified Opportunity Zone News – March 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. Legislative Updates On Capitol Hill, Opportunity Zones … Continue Reading

GT Supports NYU Winthrop Hospital’s 22nd Annual A Cause to Celebrate…Child Life

Greenberg Traurig was a proud sponsor of NYU Winthrop Hospital’s 22nd Annual “A Cause to Celebrate” on March 21, 2019, in New York. The gala honored the Founder/CEO of Fareportal, Sam Jain, and his wife, Vera Jain, for their contributions. The firm’s participation benefitted the hospital’s Child Life Program and celebrated the Jain family. Lucy S. Lee (Shareholder, Northern Virginia … Continue Reading

Lucy Lee Receives 2 Korean Tax Authority Awards

Lucy S. Lee (Shareholder, Northern Virginia and Washington, D.C., Tax) was recently recognized by the Korean Tax Authority. The Commissioner of the National Tax Service of Korea, Han Sung Hee, presented Lucy with an Award of Distinguished Service and Contribution to the advancement of international tax policies and administration, and a Plaque of Appreciation in … Continue Reading

Part 2: In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Proposed Reissuance Regulations

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. One was the finalization of the public notice regulations, and the second was the issuance of the proposed reissuance regulations, both of which have been long promised, and both of which were published in the Federal Register … Continue Reading

In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Final Public Notice and Approval Regulations

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. The first is the finalization of the public notice and approval regulations, commonly referred to as the TEFRA Regulations (the Final Regulations), and the second is the issuance of the proposed reissuance regulations. Both developments have been … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for January 2019 – Generally Trending Down

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 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

Federal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019

IRS announces the 2019 inflation-adjusted figures for gift and estate tax exemption amounts. The federal gift, estate, and GST exemption amount ( the exemption amount) is the total amount that an individual may transfer during life, or at death, without incurring gift, estate, or generation-skipping transfer tax. The exemption amount is adjusted annually for inflation, … Continue Reading

Internet Marketplaces: Effects of the New German Law regarding VAT and Online Trading

On 14 December 2018, a new German law on VAT with regard to trading goods on the Internet (link in German) was officially published and will become effective as of 1 January 2019. The law contains considerable additional VAT obligations for operators of Internet marketplaces and merchants selling goods online. In the future, operators will … Continue Reading

Florida Sales Tax on Commercial Real Property Leases Reduced Beginning January 2019

As commercial real property owners in Florida are likely aware, the Sunshine State imposes its sales tax on rental payments for the lease of real property. The general 6 percent state-level tax was reduced to 5.8 percent for 2018. The legislature passed a law to further reduce the state-level rate to 5.7 percent for occupancy … Continue Reading
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