On November 18, 2020, the IRS and Treasury Department released Revenue Ruling 2020-27 (the Revenue Ruling) stating that, if a taxpayer received a PPP Loan (defined below) and paid or incurred Eligible Expenses (defined...more
The real estate investment trust (REIT) has been a preferred vehicle for investment in income producing real estate portfolios. The REIT provides investors with many federal income tax benefits associated with C-corporations,...more
1/14/2020
/ C-Corporation ,
Choice of Entity ,
Corporate Taxes ,
Energy Sector ,
Energy Storage ,
IRS ,
K-1 ,
Master Limited Partnerships ,
Midstream Contracts ,
Offshore Drilling ,
Oil & Gas ,
Operating Leases ,
Pipelines ,
REIT ,
Tax Deductions ,
UBTI
In connection with the purchase and sale of the stock of a target corporation (a Corporate Target), the target often incurs various transaction costs (Transaction Costs) that may yield significant tax deductions (Transaction...more
6/28/2019
/ Acquisitions ,
Business Valuations ,
Complex Corporate Transactions ,
Corporate Taxes ,
Net Operating Losses ,
Purchase Agreement ,
Stock Sale Agreements ,
Target Company ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Transaction Costs
Section 162(f) of the Internal Revenue Code of 1986 (the Code), as amended by the Tax Cuts and Jobs Act (the TCJA), limits the federal income tax deductibility of certain payments made to a government or governmental entity,...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
9/12/2018
/ Acquisitions ,
Bonus Depreciation ,
Corporate Taxes ,
Energy Sector ,
International Tax Issues ,
IRS ,
MACRS ,
Property Tax ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
On August 3, 2018, the IRS and Treasury Department released proposed regulations (the Proposed Regulations) that interpret and clarify the new bonus depreciation regime under the Tax Cuts and Jobs Act (TCJA). The TCJA...more
9/4/2018
/ Acquisitions ,
Arms Length Transactions ,
Bonus Depreciation ,
Corporate Taxes ,
International Tax Issues ,
IRS ,
MACRS ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
8/31/2018
/ Acquisitions ,
Bonus Depreciation ,
Construction Industry ,
Corporate Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
MACRS ,
Pass-Through Entities ,
Proposed Regulation ,
Public Comment ,
Tax Cuts and Jobs Act ,
Tax Deductions
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
4/6/2018
/ Base Erosion Tax ,
C-Corporation ,
Corporate Taxes ,
Entertainment Industry ,
Foreign Affiliates ,
GILTI tax ,
Income Taxes ,
Limited Liability Partnerships ,
New Rules ,
Partnerships ,
Push-Out Requirements ,
Renewable Energy ,
Tax Audits ,
Tax Deductions ,
Tax Liability
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
3/16/2018
/ Base Erosion Tax ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Energy Sector ,
GILTI tax ,
Holding Periods ,
International Tax Issues ,
Pass-Through Entities ,
S-Corporation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Rates