It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more
A reverse like-kind exchange is just that, a like-kind exchange done in reverse. In a typical like-kind exchange, also known as a forward exchange, a property owner sells a property and uses the proceeds to buy a replacement...more
To avoid the manipulation of tax consequences to which transactions between certain related taxpayers may be susceptible, the IRS and the Courts generally require that such transactions be closely scrutinized to ensure that...more
Allen Matkins partner Jared Kassan participated on a panel earlier this year to discuss legal issues surrounding partnerships and 1031 exchanges. The panel began by discussing the traditional “drop and swap” strategy with its...more
In the senior living area, a taxpayer that is selling a community may look to avoid recognizing gain on the sale by entering into a Section 1031 like-kind exchange with respect to the real estate. The tax rules generally...more
Conforming- About sixty years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return...more
On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more
Long a priority of the Republican Party, the final tax cut bill includes significant simplification and lowering of the taxes paid by corporations. The bill eliminates the corporate Alternative Minimum Tax, creates a new tax...more