Income Taxes, Internal Revenue Code (IRC), Investors

Transferability of Energy Credits under the Inflation Reduction Act: What do you need to know?

Mitchell, Williams, Selig, Gates & Woodyard,... on 6/12/2024

Now that final regulations on the transferability of energy tax credits under the Inflation Reduction Act have been issued by the U.S. Department of Treasury (Treasury) and the Internal Revenue Service (IRS), many investors...more

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

WilmerHale on 6/16/2023

In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more

Indirectly Held Profits Interests and Rev. Proc. 93-27

Rivkin Radler LLP on 5/12/2023

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on 5/17/2022

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

Smith Anderson on 7/12/2021

With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

Seyfarth Shaw LLP on 4/14/2020

On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

IRS Releases Initial Guidance Regarding Section 45Q Carbon Sequestration Tax Credit

Foley & Lardner LLP on 3/12/2020

On February 20, 2020, the IRS issued its first round of guidance regarding the carbon sequestration tax credit found in Section 45Q (the “Section 45Q Credit”) of the Internal Revenue Code of 1986 (as amended, the “Code”) in...more

IRS Publishes Guidance on the Carbon Capture Tax Credit

Holland & Hart LLP on 3/3/2020

On February 19, 2020, the IRS issued two guidance items concerning the tax credit for carbon oxide sequestration (COS) under section 45Q: Notice 2020-12 and Revenue Procedure 2020-12. The new guidance is very similar to IRS...more

Carbon Capture Tax Credit Gets a Boost From IRS Guidance – A Practical Guide for Investors

Akin Gump Strauss Hauer & Feld LLP on 2/21/2020

The Internal Revenue Service (IRS) has issued the first round of guidance regarding the tax credit for carbon oxide sequestration under Internal Revenue Code Section 45Q. This guidance is divided between two documents:...more

IRS Releases Critical Guidance on Carbon Capture Tax Credits

Morgan Lewis on 2/21/2020

The guidance issued on February 19 by the Internal Revenue Service is the type that the carbon capture and storage industry had sought, and will hopefully open up the market for investment by eliminating tax-related...more

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on 12/27/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

QOZ Update: IRS Provides Relief for Early Investments of Net Section 1231 Gain

Ballard Spahr LLP on 6/28/2019

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

Treasury Provides Additional Guidance on Opportunity Zone Provisions

McDermott Will & Emery on 5/3/2019

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Additional Proposed Regulations Issued Regarding Opportunity Zones

Katten Muchin Rosenman LLP on 4/24/2019

As part of the US federal tax reform in 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the "Code"), to provide incentives economic growth and investment in designated...more

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on 4/24/2019

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Senate Finance Committee Probing Conservation Easement Abuse

Burr & Forman on 4/1/2019

On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more

Opportunity Zone Funds – Part I: Overview of the Law

Foster Garvey PC on 1/8/2019

BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more

New Guidance on Opportunity Zones: Incentives for Investments in Low-Income Communities

Holland & Knight LLP on 10/23/2018

• Holland & Knight previously published a three-part series describing the powerful new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." •...more

Opportunity Zones: How Communities Can Leverage This New Provision to Jumpstart Investment

Akin Gump Strauss Hauer & Feld LLP on 9/19/2018

• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

Global Private Equity Newsletter - Winter/Spring 2018 Edition: Snapshot of Tax Act Changes for PE Funds and their Portfolio...

Dechert LLP on 4/9/2018

President Trump signed into law tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) on December 22, 2017. The Tax Act implemented the most far-reaching changes to the Internal Revenue Code (the...more

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