This post follows up on an earlier post from December 12, 2020, titled “The Long Arm of California’s Franchise Tax Board.” That post described a recent opinion by California’s Office of Tax Appeals (OTA), Appeal of L. Mazer and M. Mazer, in which the OTA ruled in favor of the Franchise Tax Board (FTB), holding that the taxpayers were California Continue Reading …
Jon Christianson and Matthew Carlson of Boutin Jones Inc., together with Louis Weller of Weller Partners, LLP, and Richard Lipton of Baker & McKenzie, LLP, were co-authors of an article that was recently published in the February 2021 issue of the Journal of Taxation titled, “Final Regs Defining ‘Real Property’ for Section 1031: IRS Gets It Right With ‘State Law Plus.’” Continue Reading …
Real estate owned by an entity can be reassessed for California property tax purposes even with no transfer of the property. A transfer of interests in the entity resulting in a change in control or a change in ownership of the entity can result in reassessment even if the entity continues to own the real estate.
Good news from the Land of Oz: on January 19, 2021, the IRS issued Notice 2021-10, which extends the relief granted to qualified opportunity funds (“QOFs”) and their investors in previous Notice 2020-39. Notice 2021-10 (the “Notice”) extends due dates until either March 31, 2021 or June 30, 2021, in response to the continued challenges posed by the coronavirus pandemic.
The Notice Continue Reading …
Intro. The residential real property market has been active recently for rental houses and principal residences It is perhaps for this reason that I have received several inquiries about the use of IRC Section 121 to exclude gain, the use of IRC Section 1031 to defer gain, and the potential use of both sections in a single transaction. This short post Continue Reading …