Virginia Governor Ralph Northam announced that “while filing deadlines remain the same, the due date for payment of individual and corporate income tax will now be June 1, 2020.” However, the Virginia extension to pay, while...more
On March 18, 2020, the California Franchise Tax Board (FTB) further postponed its state tax filing and payment deadlines to July 15 for all individuals and business entities for 2019 tax returns and payments, 2020 first and...more
Following U.S. Treasury Secretary Steve Mnuchin’s announcement via Twitter on Friday, March 20, that Treasury would be moving Tax Day from April 15 to July 15, New York Governor Andrew Cuomo’s Budget Director Robert Mujica...more
The City of Philadelphia Revenue Department announced administrative extensions to the due dates for 2020 real estate taxes (originally due March 31, 2020) and 2019 business taxes (originally due April 15, 2020)....more
In guidance available on its website, the Pennsylvania Department of Revenue announced extensions for personal income tax (PIT) returns and payments due April 15, 2020, until July 15, 2020 (conforming to similar IRS...more
As a result of the ongoing coronavirus disease (COVID-19) pandemic, the IRS granted taxpayers a limited extension to pay income taxes that are due on April 15, but there is no extension of the April 15 filing deadline. Tax...more
Following Treasury Secretary Steve Mnuchin’s Twitter announcement that Tax Day would be moved from April 15 to July 15, 2020, in response to the ongoing coronavirus crisis, the IRS released Notice 2020-18 (available here)...more
3/23/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Federal Taxes ,
Filing Deadlines ,
Guidance Update ,
Income Taxes ,
IRS ,
Relief Measures ,
Tax Extensions ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
In response to the COVID-19 crisis, Treasury Secretary Steve Mnuchin announced via Twitter that Treasury is “moving Tax Day from April 15 to July 15. All taxpayers and businesses will have this additional time to file and...more
3/20/2020
On Wednesday, March 18, 2020, the Families First Coronavirus Response Act (FFCRA or the Act) became law. While only a small portion of the Act affects taxes, the Act provides federal tax credits for paid sick leave and family...more
The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more
1/15/2020
/ Capital Gains ,
Carried Interest ,
Carried Interest Tax Rates ,
Community Development ,
Economic Development ,
Final Rules ,
Grace Period ,
Incentives ,
Intangible Property ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Pass-Through Entities ,
Property Improvements ,
Property Valuation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Real Estate Transactions ,
Regulatory Requirements ,
Retail Installment Sales Contracts ,
Statutory Interpretation ,
Step-Up Basis ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
U.S. Treasury
In Duffield House LP v. City of Philadelphia–a case involving assessment appeals by approximately 700 owners and lessees of commercial and industrial properties in the City–Philadelphia County Court of Common Pleas Judge Gene...more
Act 13 of 2019 (Act 13), signed by Governor Wolf on June 28, 2019, made several changes to Pennsylvania tax laws, including the following significant changes.
...more
7/17/2019
/ Capital Gains ,
Corporate Taxes ,
Economic Development ,
Income Taxes ,
New Legislation ,
Opportunity Zones ,
Sales & Use Tax ,
State and Local Government ,
Tax Credits ,
Tax Deductions ,
Tax Planning ,
Transfer Taxes
The IRS has published Final Regulations finalizing its prior guidance that partners in a partnership must pay self-employment tax on their partnership income, even if they work for an entity owned entirely by the partnership...more
There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.
Internal Revenue Code Section 1231 applies to depreciable property and...more
6/28/2019
/ Capital Gains ,
Community Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning
The IRS recently published Final Regulations and Notice 2019-12 largely blocking state efforts to circumvent limitations on deductions for state and local taxes. (See our alert on the Proposed Regulations, issued in August...more
6/27/2019
/ Business Taxes ,
IRS ,
Itemized Deductions ,
Liability Caps ,
Local Taxes ,
New Regulations ,
SALT ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Planning ,
Tax Reform
Mayor Kenney on May 15 signed into law a bill amending the Philadelphia Realty Transfer Tax as it applies to sales of interests in real estate companies. Before July 1, 2017, if a real estate company that owned Philadelphia...more
OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM -
The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Corporate Entities ,
Investment Opportunities ,
Investment Property ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Reinvestment Funds ,
Rollover Equity ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax-Deferred Exchanges ,
U.S. Treasury
The Tax Cuts and Jobs Act introduced a new tax-incentive program known as Qualified Opportunity Zones (QOZs). In 2018, governors of all 50 states, the District of Columbia, and the five U.S. possessions designated more than...more
10/26/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Rollover Equity ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
Trump Administration
The IRS proposed regulations (the Proposed Regulations) on August 23, 2018, that would largely block state efforts to circumvent new limitations on income tax deductions for state and local taxes and would affect many current...more
Pennsylvania Governor Tom Wolf signed Act 72 of 2018 into law last week. Act 72 will allow Pennsylvania corporate net income tax (CNIT) taxpayers to use the federal Modified Accelerated Cost Recovery System (MACRS), but not...more
The U.S. Supreme Court, in South Dakota v. Wayfair, Inc., reversed the long-standing rule that physical presence by a vendor is necessary for a state to require the vendor to collect sales tax on taxable goods and services...more
6/27/2018
/ Appeals ,
Commerce Clause ,
Constitutional Challenges ,
Internet Retailers ,
Interstate Commerce ,
Out-of-State Companies ,
Physical Presence Test ,
Quill ,
Reversal ,
Sales & Use Tax ,
SCOTUS ,
South Dakota v. Wayfair ,
Substantial Nexus
The IRS has now certified and designated Qualified Opportunity Zones (QOZs) in every state, five possessions, and the District of Columbia....more
6/19/2018
/ Community Development ,
Economic Development ,
Investment Funds ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
The Pennsylvania Department of Revenue (the Department) published an Information Notice setting forth its position as to how the repatriation income and deduction under Section 965 of the Internal Revenue Code (the Code) (the...more
The IRS released Opportunity Zone FAQs on April 24 explaining that an eligible entity will be able to self-certify to become a Qualified Opportunity Fund (QOF) by filing a form (to be released this summer) with its timely...more
5/8/2018
/ Community Development ,
Economic Development ,
Investment Funds ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Public Finance ,
Self-Certification ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration
The IRS inaugurated an exciting new community redevelopment program on April 9 and April 18 when it designated more than 4,800 Qualified Opportunity Zones (QOZs) in 20 states, three possessions, and Puerto Rico....more
4/25/2018
/ Community Development ,
Economic Development ,
Investment Funds ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Trump Administration