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amnesty

New Jersey Tax Amnesty

Applicable Federal Rates (AFRs)

Applicable Federal Rates and Code Section 7520 Rate for October 2019 – Downward Trend AcceleratesApplicable Federal Rates and Code Section 7520 Rate for September 2019 – Downward Trend ContinuesApplicable Federal Rates and Code Section 7520 Rate for July 2019 – Downward Trend Continues

awards

Marvin Kirsner Recognized as National Law Review ‘Go-To Thought Leader’ for Tax LawGreenberg Traurig Tax & Private Wealth Services Attorneys Listed in the Best Lawyers 202129 GT New York Attorneys Listed in 2020 Edition of Best Lawyers in America, Including Barbara Kaplan as Lawyer of the Year

Blockchain

Sales Tax on NFTs: Washington State Guidance Blazes Trail Other States May FollowPallav Raghuvanshi Quoted in Thomson Reuters Article, 'The Long Read: Catching Up With Crypto'A Recent Court Case Leaves Many Speculating on the Taxation of Staking Rewards

Brexit

GTM Alert - Brexit: The Timeline

California

California SB 113 Eliminates Suspension on NOL Deductions, Lifts Limitation on Use of Tax Credits, and Expands Elective Pass-Through Entity TaxCalifornia Property Tax Exemptions for Nonprofits – Annual Filings Due Feb. 15, 2022Brad Marsh Speaks at North County Bar Association

California Taxation of Asset Management Fees

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

Charitable Planning

House Proposal Targets Charitable Deductions for Conservation Easements by Passthrough EntitiesGreenberg Traurig's Barbara Kaplan, Michelle Ferreira, and Jennifer Vincent Featured in Law360Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

Cloud Transactions

Sales Tax on NFTs: Washington State Guidance Blazes Trail Other States May FollowIRS Aims to Catch Up to Tech AdvancementsIRS Clarifies U.S. Tax Treatment of Cross-Border Cloud and Other Online Transactions in Proposed Regulations

Code Section 956

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. ShareholdersIRS Issues Proposed Section 956 Regulations Relating to Foreign Subsidiary Guarantees and Stock Pledges

Congress

How the Inflation Reduction Act May Impact the Renewable Energy IndustryBipartisan Proposed Legislation Released for Qualified Opportunity Zone InvestmentsHouse Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities

controlled foreign corporation

IRS and Treasury Issue Final IRC Section 956 Regulations that Reduce Deemed Income Inclusion for Certain Corporate U.S. ShareholdersIRS Issues Proposed Section 956 Regulations Relating to Foreign Subsidiary Guarantees and Stock Pledges

cryptocurrency

Sales Tax on NFTs: Washington State Guidance Blazes Trail Other States May FollowPallav Raghuvanshi Quoted in Thomson Reuters Article, 'The Long Read: Catching Up With Crypto'IRS Announces Revisions to the Application Form for Voluntary Disclosures with New Provisions for Cryptocurrency, Employment Tax, and Estate, Gift and Generation-Skipping Transfer Tax

Death and Disability Planning

SECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsEffect of Kaestner on Non-California Trusts With California BeneficiariesMaking Final Arrangements for Funerals and Dispositions of Remains

Death Taxes

Effect of Kaestner on Non-California Trusts With California BeneficiariesFederal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019Maryland Reduces Evidentiary Requirements to Exempt Primary Residence of Domestic Partners from Inheritance Tax

Estate

Uncertainty, COVID-19, and Estate Planning: A Unique Opportunity to PlanSECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsEffect of Kaestner on Non-California Trusts With California Beneficiaries

Estate Planning

Uncertainty, COVID-19, and Estate Planning: A Unique Opportunity to PlanSECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsEffect of Kaestner on Non-California Trusts With California Beneficiaries

Estate Tax

IRS Announces Revisions to the Application Form for Voluntary Disclosures with New Provisions for Cryptocurrency, Employment Tax, and Estate, Gift and Generation-Skipping Transfer TaxSECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsApplicable Federal Rates and Code Section 7520 Rate for January 2019 – Generally Trending Down

European Union (EU)

EU’s DAC7: New Tax Reporting Obligations for Platform OperatorsDutch Presented Tax Measures for 2022The Netherlands and Germany Amend Tax Treaty

Event

Glenn Newman to Present on 'State Income Tax Issues and Implications of Remote Working'Brad Marsh Speaks at North County Bar AssociationJames Lang to Moderate Panel at In-Person 2021 Opportunity Zone Expo

FATCA

FATCA Proposed Regulations

Featured

New York Provides Tax Credit for Video Game ProductionHow the Inflation Reduction Act May Impact the Renewable Energy IndustrySales Tax on NFTs: Washington State Guidance Blazes Trail Other States May Follow

Firm News

Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory ResidencyJames O. Lang Named a 'Top 25 OZ Attorney' by Opportunity Zone MagazineMagan Ray Re-elected to American Civil Liberties Union of Northern California Board of Directors

Florida

Florida Requires Sales Tax Collection on All In-Person and Online Sales, Effective July 1Florida Sales Tax on Commercial Real Property Leases Reduced Beginning January 2019

Foreign Account Tax Compliance Act

IRS Secures Two Court Victories Involving Foreign Financial ActivityFATCA Proposed Regulations

foreign investment tax

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

Germany

The Netherlands and Germany Amend Tax TreatyInternet Marketplaces: Effects of the New German Law regarding VAT and Online Trading

Gifts

Applicable Federal Rates and Code Section 7520 Rate for January 2019 – Generally Trending DownFederal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019Applicable Federal Rates and Code Section 7520 Rate for November 2018 – Trending Up

Government

District Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66The Saga Continues in CIC Services v. IRS: Government Moves to Prevent IRS from Returning Disclosure Documents Obtained from Nonparties Under Notice 2016-66Bipartisan Proposed Legislation Released for Qualified Opportunity Zone Investments

GT Alert

New York Provides Tax Credit for Video Game ProductionHow the Inflation Reduction Act May Impact the Renewable Energy IndustryIRS 90-Day Pre-Examination Compliance Pilot

Incentive Trusts

SECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsIncentive Trusts Can Be Used to Provide Guidance to Your Trustee and Incentivize Beneficiaries

Income Tax

Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory ResidencyAnother Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. CommissionerDutch Presented Tax Measures for 2022

Individual Retirement Accounts

SECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsGreenberg Traurig’s Diana Zeydel Featured in the Wall Street Journal

Inheritance Rights

SECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsEffect of Kaestner on Non-California Trusts With California BeneficiariesFederal Individual Gift, Estate, and GST Exemptions Increase to $11.4 Million in 2019

Insurance

Another Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. CommissionerIRS Establishes Office of Promoter Investigations with Emphasis on Conservation Easements and Micro-captive Insurance ArrangementsIRS Wins Again on Micro-Captive Arrangements, Urges Taxpayers to Exit Transactions

Internal Revenue Code

Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This MonthLate Payment of Deferred Payroll Taxes Under CARES Act Could Result in Harsh ConsequencesHouse Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities

International Tax

The Netherlands and Colombia Have Signed a Tax TreatyDutch Presented Tax Measures for 2022IRS Secures Two Court Victories Involving Foreign Financial Activity

internet marketplace

Florida Requires Sales Tax Collection on All In-Person and Online Sales, Effective July 1Internet Marketplaces: Effects of the New German Law regarding VAT and Online Trading

Intestate Succession

State Law on After-born Children Leads to Revocation of a Will

Investing

Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action IncreasesProposed Regulations for Qualified Foreign Pension Funds that are Exempt from U.S. Tax on Disposition of U.S. Real Property InterestsI Won the Lottery! What Do I Do Now?

IRS

IRS 90-Day Pre-Examination Compliance PilotAnother Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. CommissionerDistrict Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66

Labor & Employment

IRS 90-Day Pre-Examination Compliance PilotEmployee Retention Credit Terminated Early Retroactive to Oct. 1 by Infrastructure Act – No Penalty Relief or Time to Pay Back Advance CreditPossible Early End to Employee Retention Tax Credit Could Mean Trouble for Businesses Monetizing Credit Before End of 4th Quarter

Legacy Planning

Michelle Ferreira Quoted in Law360 article, ‘Careful Evaluation Needed Before Acceptance Of Easement Deals’Lenders Should Not Report PPP Loan Forgiveness to IRS or to BorrowersDutch 2021 Tax Bill Presented

lottery

I Won the Lottery! What Do I Do Now?

New Jersey

Residency Audits: What To Expect When You Move To Another StateNew Jersey Tax Amnesty

Opportunity Zones

Bipartisan Proposed Legislation Released for Qualified Opportunity Zone InvestmentsJames O. Lang Named a 'Top 25 OZ Attorney' by Opportunity Zone MagazineU.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit Awards

qualified opportunity funds

James O. Lang Named a 'Top 25 OZ Attorney' by Opportunity Zone MagazineU.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit AwardsJames Lang to Moderate Panel at In-Person 2021 Opportunity Zone Expo

qualified opportunity zones

Bipartisan Proposed Legislation Released for Qualified Opportunity Zone InvestmentsJames O. Lang Named a 'Top 25 OZ Attorney' by Opportunity Zone MagazineU.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit Awards

Real Estate

U.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit AwardsPandemic-Driven Devalued Retail Real Estate Owners Should Seek Property Tax ReductionsFlorida Requires Sales Tax Collection on All In-Person and Online Sales, Effective July 1

real estate tax

U.S. Treasury Announces $5 Billion Allocation of New Markets Tax Credit AwardsPandemic-Driven Devalued Retail Real Estate Owners Should Seek Property Tax ReductionsFlorida Requires Sales Tax Collection on All In-Person and Online Sales, Effective July 1

Revocable Trust

State Law on After-born Children Leads to Revocation of a WillA Revocable Trust Worked for Coach Dean Smith, Why Not You?

Sales Tax

Sales Tax on NFTs: Washington State Guidance Blazes Trail Other States May FollowState Sales Tax on Sale of Non-Fungible Tokens (NFTs) – Questions and AnswersFlorida Requires Sales Tax Collection on All In-Person and Online Sales, Effective July 1

Section 338(h)(10) Elections

GT’s Quick Guide to Section 338(h)(10) Elections

Self-Correction Program

IRS Expands Retirement Plan Self-Correction Program

State Tax

New York Provides Tax Credit for Video Game ProductionSales Tax on NFTs: Washington State Guidance Blazes Trail Other States May FollowGreenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory Residency

tax audits

Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory ResidencyDistrict Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66House Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities

Tax Cuts and Jobs Act

James Lang to Moderate Panel at In-Person 2021 Opportunity Zone ExpoNon-Recourse Financing Can Imperil Tax Deductions: The Application of the Internal Revenue Code ‘At-Risk’ Rules to Aircraft PurchasesResidency Audits: What To Expect When You Move To Another State

Tax Planning

Employee Retention Credit Terminated Early Retroactive to Oct. 1 by Infrastructure Act – No Penalty Relief or Time to Pay Back Advance CreditDutch Presented Tax Measures for 2022The IRS Announced a New Non-Filer Initiative Over a Year Ago - Now We See the Enforcement

tax withholding

Dutch Presented Tax Measures for 2022The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service ProvidersThe Netherlands and Chile Sign a Tax Treaty

tax-exempt bonds

Tax-Exempt Bond Tools for Governments Facing Cash Flow and Revenue Challenges – Part IIVeterans Housing Preference Permitted Under IRC Section 42 Now Permitted Under 142Part 2: In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Proposed Reissuance Regulations

Trusts

SECURE Act Accelerates Timing of Required Minimum Distributions to Beneficiaries Under Qualified Plans and IRAsEffect of Kaestner on Non-California Trusts With California BeneficiariesI Won the Lottery! What Do I Do Now?

Tuition

529 Plans – Tools for Financing a College Education

Uncategorized

James Lang to Moderate Panel at In-Person 2021 Opportunity Zone ExpoThe IRS Announced a New Non-Filer Initiative Over a Year Ago - Now We See the Enforcement3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Proposed Regulations

VAT

Tax Hurdles on Equine AcquisitionsInternet Marketplaces: Effects of the New German Law regarding VAT and Online Trading

VAT Tax

Tax Hurdles on Equine AcquisitionsInternet Marketplaces: Effects of the New German Law regarding VAT and Online Trading

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