April 9, 2020: The Treasury Department and the Internal Revenue Service issued Notice 2020-23, which amplified Notice 2020-18 and Notice 2020-20 and modified Rev. Proc. 2014-42 with respect to calendar year 2020, and provided additional relief, postponing certain time-sensitive actions. Generally, Notice 2020-23 provides that any person who has a federal tax return or other form filing obligation specified in the Notice that is due to be performed (originally or pursuant ... Keep Reading »
Qualified Opportunity Zones vs. 1031
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 »
Seizing the Opportunity with Qualified Opportunity Zones
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 »