The Tax of Life

  • All Topics
  • Contributors
  • About
  • Contact
  • Subscribe
You are here: Home / Archives for Larry Kemm

About Larry Kemm

Larry Kemm is of counsel at Carlton Fields in Tampa, Florida. Connect with Larry on LinkedIn.

Qualified Opportunity Zones vs. 1031

January 30, 2019 by Larry Kemm and Cristin Keane

For years, Code § 1031 has been a popular way to defer taxation on the sale of capital gain assets. However, Code § 1031 has significant requirements, including complex timing and identification requirements and a requirement that the capital gain asset be exchanged with “like kind” property that, as of the enactment of the so-called Tax Cuts and Jobs Act in 2017, must be real property. With the enactment of Code §§ 1400Z-1 and 1400Z-2 in the Tax Cuts and Jobs Act, the ... Keep Reading »

Filed Under: Qualified Opportunity Zone

Seizing the Opportunity with Qualified Opportunity Zones

January 30, 2019 by Larry Kemm and Cristin Keane

The December 2017 tax legislation commonly referred to as the Tax Cuts and Jobs Act (the Act) provides significant tax incentives for taxpayers to invest in certain low-income communities designated as Qualified Opportunity Zones under Code Section 1400Z-1. Proposed regulations published by the U.S. Department of the Treasury in October 2018 provide additional guidance regarding Qualified Opportunity Zone investments (the Proposed Guidance). The following analysis is ... Keep Reading »

Filed Under: Qualified Opportunity Zone

Cost-Sharing Regulations Revived By Ninth Circuit

July 31, 2018 by Larry Kemm

The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory provisions previously invalidated by the Tax Court. (See Altera Corp. v. Commissioner, Dkt. Nos. 16-70597 & 16-70497 (9th Cir. 2018) rev’g 145 T.C. 91 (2015)). These regulations govern the allocation of stock-based compensation costs to a foreign ... Keep Reading »

Filed Under: International Tax, Tax Controversy

Tax Reform: Insurance Company Provisions

April 13, 2018 by Larry Kemm

Recent tax legislation, informally known as the Tax Cuts and Jobs Act (the “Act”) contains several changes that affect the insurance industry. A centerpiece of the Act lowers the corporate income tax rate to 21 percent, which generally applies to all corporations. Other reforms not specific to the insurance industry will also significantly affect many insurance companies. These include eliminating the corporate alternative minimum tax, a reduction of the general ... Keep Reading »

Filed Under: Federal Income Tax, Tax Controversy

BEPS Developments Usher in New Era of International Taxation

October 6, 2017 by Larry Kemm

Four years after the OECD and G20 countries adopted a 15-point action plan to attack base erosion and profit shifting (BEPS), a new era of international taxation was launched on June 7 when 68 countries signed a multilateral instrument. Several additional countries are committed to sign in the near future. The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is significant because it enables the rapid ... Keep Reading »

Filed Under: International Tax

  • 1
  • 2
  • Next Page »

Carlton Fields Logo

A blog focused on recent developments in tax law by the attorneys of Carlton Fields.

Focused Topics

  • Employee Benefits
  • Estate and Gift Tax
  • Federal Income Tax
  • International Tax
  • LLCs and Partnerships
  • Qualified Opportunity Zone
  • State and Local Tax
  • Tax Exempt Organizations
  • Tax Controversy

Recent Articles

  • How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
  • COBRA Deadlines and Proofs of Mailing in Carter v. Southwest Airlines Co. Board of Trustees
  • Midyear Premium Increases and Cafeteria Plan Rules

Get Weekly Updates!

Receive articles straight to your inbox, every Monday at 8:00 A.M.

Carlton Fields

  • carltonfields.com
  • Practices
  • Industries
  • ExpectFocus Magazine

Related Practices

  • Taxation
  • Tax Litigation and Controversy

About Tax of Life

  • All Topics
  • Contributors
  • About
  • Contact
© 2014–2023 Carlton Fields, P.A. · Carlton Fields practices law in California as Carlton Fields, LLP · All Rights Reserved · Privacy Policy · Disclaimer

Carlton Fields publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information and educational purposes only, and should not be relied on as if it were advice about a particular fact situation. The distribution of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship with Carlton Fields. This publication may not be quoted or referred to in any other publication or proceeding without the prior written consent of the firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please contact us. The views set forth herein are the personal views of the author and do not necessarily reflect those of the firm. This site may contain hypertext links to information created and maintained by other entities. Carlton Fields does not control or guarantee the accuracy or completeness of this outside information, nor is the inclusion of a link to be intended as an endorsement of those outside sites. This site may be considered attorney advertising in some jurisdictions.