News & Analysis as of

Internal Revenue Service Property Owners Internal Revenue Code (IRC)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

Polsinelli on

In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more

Holland & Knight LLP

Treasury, IRS Release Section 30C Alternative Fuel Vehicle Refueling Property Credit Guidance

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Jan. 19, 2024, released Notice 2024-20, stating their intent to issue proposed regulations regarding the Alternative Fuel Vehicle Refueling Property Credit under Section 30C of...more

Tonkon Torp LLP

Section 1031: What Is Real Property? Four Things You Should Know From The New Final Regulations

Tonkon Torp LLP on

Effective December 2, 2020, the IRS issued its Final Regulations (the “Final Regs”) clarifying what is real property under Section 1031 of the Internal Revenue Code. The IRS issued these regulations to provide guidance in...more

Foster Garvey PC

Opportunity Zone Funds – Part III: Lots of Questions But Few Answers

Foster Garvey PC on

There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more

Holland & Knight LLP

The New Tax Law: Impact on Illinois Local Governments

Holland & Knight LLP on

The new tax reform law – the Tax Cuts and Jobs Act – has been extensively reported in a variety of media outlets. Most discussions focus on the reduction in individual and corporate tax rates, the availability of deductions...more

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