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Supreme Court Issues Ruling Affecting Valuation of Closely Held Corporations Employing Life-Insurance-Funded Redemption-Type...

Improperly structured buy-sell agreements for closely held businesses will lead to an unexpected increase in the estate tax imposed on the estate of the deceased owner. The Supreme Court decision emphasizes the need for a...more

Renewable Energy Tax Credits under the Inflation Reduction Act: Opportunities for Exempt Organizations

The Inflation Reduction Act of 2022 (the “IRA” or “Act”) added and modified several renewable energy tax provisions under the Internal Revenue Code of 1986, as amended (the “IRC”).[1] These changes provide many opportunities...more

Applying the Opportunity Zone Program in the Wake of the COVID-19 Pandemic

In December 2019, the Treasury released final regulations for the opportunity zone program (the "Final Regulations") to refine and clarify certain aspects of the first two sets of proposed regulations and to make the rules...more

IRS Publishes Final Opportunity Zone Regulations

On December 19, 2019, the Treasury Department and Internal Revenue Service (the “IRS”) released final regulations for the opportunity zone (“OZ”) program to refine and clarify certain aspects of the first two sets of proposed...more

IRS Publishes Second Set of Opportunity Zone Proposed Regulations

The Internal Revenue Service and the Treasury Department recently released a second tranche of proposed regulations that provide additional guidance on the tax incentives of investing in opportunity zones, including the...more

IRS Publishes Opportunity Zone Proposed Regulations: The First Important Step in the Structuring of OZ Funds

As part of the Tax Cuts and Jobs Act (the “TCJA”), a new tax incentive program was created to spur economic growth and investment in designated distressed communities (each an “opportunity zone” or “OZ”). Not only does the OZ...more

Practical Issues Facing Nonprofits Structuring New Market Tax Credit Deals

Since the Great Recession, nonprofits have been receiving less support from budget-constrained governmental agencies and fewer contributions from the private sector. Similarly, many state and other nonprofit universities have...more

Foundation: December 2016 • Vol. IV , Issue 3

We are pleased to present our last edition of Foundation for the year, and hope that you have enjoyed the issues we have put together in 2016. We have worked hard to provide you with timely and relevant articles in a...more

IRS Issues Guidance on Section 50(d) Income Inclusion Rules

Action Item: The recently issued temporary Treasury Regulation § 1.150-1T contains guidance that is significant to businesses and individuals alike. Transactions involving master lease pass-throughs may require special...more

Act Now to Avoid Proposed IRS Rules Which Would Eliminate Valuation Discounts for Intra-Family Transfers of Interests in Family...

Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...more

Treasury Department Issues New PRI Regulations

Foundations must understand the final Program Related Investment regulations and ensure that their planned and ongoing investments comply with the most recent IRS guidance to ensure their investments do not jeopardize their...more

Annual Estate Planning Newsletter: Part Six

Action Item: This is the sixth and final installment of our Annual Estate Planning Newsletter, and focuses on estate planning matters not related to tax planning. We urge you to review this installment to ensure that your...more

Annual Estate Planning Newsletter: Part Five

Action Item: This is the fifth installment of our Annual Estate Planning Newsletter, and focuses on foreign matters. We urge you to review this installment to ensure that your 2016 estate and tax planning is in...more

Annual Estate Planning Newsletter: Part Four

Action Item: This is the fourth installment of our Annual Estate Planning Newsletter, and focuses on matters of interest to married couples. We urge you to review this installment to ensure that your 2016 estate and tax...more

Annual Estate Planning Newsletter: Part Three

Action Item: This is the third installment of our Annual Estate Planning Letter, and covers some topics of interest not discussed in our previous installments. We urge you to review this installment to ensure that your 2016...more

Annual Estate Planning Newsletter: Part Two

Action Item: This is the second installment of our Annual Estate Planning Newsletter, and focuses on specific gift and generation-skipping transfer ("GST") tax matters. We urge you to review this installment to ensure that...more

Congress Passes Protecting Americans from Tax Hikes (Path) Act of 2015, Making Many Tax Extenders Permanent

Action Item: The recently enacted PATH Act contains key tax provisions for businesses and individuals alike, including permanently expanding Section 179 of the Internal Revenue Code; extending the availability of...more

Annual Estate Planning Newsletter: Part One

Action Item: This year, Blank Rome’s annual estate planning newsletter will be issued in six installments. Each installment will discuss certain concepts and techniques that we hope may be of interest to our clients and...more

Real Estate: Foundation - April 2015

In this issue: - How NMTCs Benefit Real Estate Community Development Initiatives - Noteworthy Real Estate Deals - What’s Your Priority? An Open-Ended Examination of Pennsylvania’s Mechanics’ Lien...more

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