Tag Archives: IRS

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

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

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

IRS Extends Income Tax Filing Deadline to July 15, 2020, and Removes Cap on Tax Payments Deferred to July 15, 2020

On March 20, 2020, the IRS issued Notice 2020-18, extending the April 15, 2020, due date for filing federal income tax returns and making federal income tax payments to July 15, 2020, for all affected taxpayers. IRS Notice 2020-18 supersedes IRS Notice 2020-17, which was issued two days earlier, on March 18, 2020, and provided for a … Continue Reading

IRS Takes First Steps to Implement Carbon Capture Tax Credit

On Feb. 19, 2020, the Internal Revenue Service released partial guidance on the implementation of section 45Q tax credits related to the capture and sequestration of carbon dioxide. The section 45Q tax credit was updated on Feb. 9, 2018, as part of the Bipartisan Budget Act (Pub. L. 115-123) to increase the amount of the … Continue Reading

IRS to Increase Enforcement Against Abusive Micro-Captive Insurance Transactions

Emboldened by significant victories in three Tax Court cases involving micro-captive insurance companies, on Jan. 31, 2020, the IRS announced that it is establishing 12 new examination teams to assist in the audits of abusive micro-captive insurance transactions. The IRS expects the audit teams to immediately begin new examinations that will impact several thousand taxpayers involved in … Continue Reading

2019 Tax Act Effects on Tax-Exempt Organizations; Required Section 501(c)(4) Notices

The Tax Cuts and Jobs Act included a provision increasing taxes on tax-exempt organizations. New Internal Revenue Code Section 512(a)(7) required that tax-exempt organizations include in computing unrelated business taxable income any amount incurred by the tax-exempt organization (i) for any qualified transportation fringe benefit for an employee (generally, costs of mass transit passes and … 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

In the Zone: GT Qualified Opportunity Zone News – December 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.… Continue Reading

Final IRS Guidance for Rental Deduction Still Leaves Triple Net Leases Out in the Cold

Many real estate investors hoping for clarity on whether they will be eligible for the tax break for pass-through entities under the Tax Cuts and Jobs Act (TCJA) will be disappointed that guidance from the Internal Revenue Service (IRS) will not help much for projects leased on a triple-net basis. Read Marvin A. Kirsner’s article … Continue Reading

Greenberg Traurig’s Barbara Kaplan, Michelle Ferreira, and Jennifer Vincent Featured in Law360

Law360 recently published an article by Greenberg Traurig’s Barbara T. Kaplan, Michelle Ferreira, and Jennifer Vincent, titled “Prepare For Greater IRS Scrutiny On Conservation Easements.” While the Internal Revenue Service has been focused on syndicated conservation easements for over 10 years, earlier this year IRS Commissioner Chuck Rettig announced several campaign issues on which the … 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

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

Applicable Federal Rates and Code Section 7520 Rate for October 2019 – Downward Trend Accelerates

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

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

The Internal Revenue Service (IRS) publishes monthly the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for the month following the month in which the Revenue Ruling is published in a Revenue Ruling that is released around the 18th day of the immediately preceding month. … 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

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
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