Tag Archives: gtlaw

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

29 GT New York Attorneys Listed in 2020 Edition of Best Lawyers in America, Including Barbara Kaplan as Lawyer of the Year

The New York office of global law firm Greenberg Traurig, LLP has 29 attorneys listed in the 2020 edition of Best Lawyers in America. Additionally, Tax Practice Co-Chair Barbara Kaplan was named “Lawyer of the Year” for Litigation and Controversy in Tax.  To read full press release, click here.… 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

In the Zone: GT Qualified Opportunity Zone News – June 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. AROUND D.C.: GT Client Kyle Walker (Principal, … Continue Reading

Applicable Federal Rates and Code Section 7520 Rate for July 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

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

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

IRS Expands Retirement Plan Self-Correction Program

Our January 2019 GT Benefits and Compensation Alert addressed the unprecedented level of potential liability for compliance failures in 401(k) and other retirement plans and the importance of performing a plan compliance review and correcting plan document or operational failures before an IRS auditor knocks on the door. Doing nothing and playing the audit lottery … 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
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