Initially, tracking systems were employed to monitor the private jet usage of celebrities like Taylor Swift. Now, similar scrutiny will extend to executives who utilize business aircraft for personal purposes while claiming...more
In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more
As we move into the final quarter of 2022, it is critical to take note of an expiring tax benefit in the Tax Cuts and Jobs Act (TCJA). Passed in 2017, it allows for 100% bonus depreciation on a wide variety of capital assets...more
On September 21, 2020, the IRS and Treasury Department released the last set of final regulations (the 2020 Final Regulations) under the bonus depreciation rules of Section 168(k) of the Internal Revenue Code (the Code). ...more
One of the key tax benefits for investors and owners of real estate such a senior living facilities is depreciation. The 2017 Tax Cuts and Jobs Act expanded on this benefit, allowing for 100% bonus depreciation for assets...more
The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more
On April 17, 2020, the IRS released Rev. Proc. 2020-25, which provides procedural guidance to secure bonus depreciation with respect to qualified improvement property (QIP) made by the CARES Act. Due to a scrivener’s error in...more
On September 13, 2019, the IRS and Treasury Department released final regulations (the Final Regulations) and new proposed regulations (the New Proposed Regulations) that interpret and clarify the regime for immediate...more
On September 13, 2019, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued final and reproposed regulations under § 168(k) of the Internal Revenue Code (Code), the provision of the Tax Cuts...more
The restaurant, retail and hospitality industries, among others, will be negatively affected by the qualified improvement property (QIP) drafting error in the Tax Cuts and Jobs Act (TCJA) (P.L. 115-97). This mistake will...more
The Internal Revenue Service (IRS) has released a Notice regarding the tax treatment of meals, and the National Business Aviation Association (NBAA) has submitted comments to the IRS regarding the proposed regulations on...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
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
The Internal Revenue Service (IRS) and Department of the Treasury recently proposed regulations that shed light on how the new, expanded bonus depreciation regime may work in the context of many common acquisitions involving...more
The Tax Cuts and Jobs Act (TCJA) expanded bonus first-year depreciation for qualifying property up to 100 percent of the adjusted basis of the property (the Bonus Depreciation Deduction)....more
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more
The IRS and Treasury have released proposed regulations concerning the first-year bonus depreciation deduction, also known as immediate expensing. The proposed regulations reflect changes made to bonus depreciation rules by...more
Since 2002, bonus depreciation under the Job Creation and Worker Assistance Act has been allowed in some form. Bonus depreciation allows for more current expensing for eligible property than allowed under the current...more