Tax Articles

12 07, 2021

IRS Excludes Cryptocurrency Exchanges From Section 1031

2021-07-12T18:06:14+00:00July 12th, 2021|Tax Articles|

Cryptocurrency is cool these days. And since this Tax Blog aspires to be cool (with mixed results), allow me to examine the latest offering from the IRS regarding cryptocurrency. Under the heading of “better late than never,” in General Counsel Memorandum 202124008, published June 8, 2021 (the “Memo”) the IRS published guidance stating that pre-2018 exchanges among Bitcoin, Ether, and Litecoin Continue Reading

7 06, 2021

Revenue Ruling 99-6 and Section 1031: Bob and Jon’s Excellent Adventure—Part II

2021-06-07T19:20:42+00:00June 7th, 2021|Tax Articles|

Bob and Jon were the members of Apartment LLC, an LLC taxed as a partnership, with Bob owning a 40% membership interest and Jon owning a 60% membership interest. Apartment LLC owned a small apartment building as its only asset. Things were going well with the apartment building.

One day Bob decided he would liquidate his assets and move to Mexico, where Continue Reading

26 05, 2021

Revenue Ruling 99-5 and Section 1031: Bob and Jon’s Excellent Adventure—Part I

2021-05-26T19:14:33+00:00May 26th, 2021|Tax Articles|

Jon was the sole member of Apartment LLC, a disregarded entity for tax purposes. Apartment LLC owned a small apartment building as its only asset. Things were going well with that apartment building.

Bob had some extra cash from golf winnings and was looking for a real estate investment. He saw how well Jon’s apartment building was doing, and asked if he Continue Reading

27 04, 2021

Rev. Proc. 2021-20: A Safe Harbor for Missed PPP Deductions

2021-04-28T17:35:54+00:00April 27th, 2021|Tax Articles|

On April 22, 2021, the IRS issued Revenue Procedure 2021-20, which provides a safe harbor allowing taxpayers who did not deduct expenses paid with forgiven PPP loans in 2020 to deduct those expenses in the next tax year. The failure to deduct those expenses was consistent with IRS guidance at the time, but that guidance was superseded by the COVID-Related Tax Continue Reading

8 04, 2021

Tax Provisions in the American Rescue Plan Act of 2021

2021-04-08T02:25:12+00:00April 8th, 2021|Tax Articles|

On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”), a $1.9 trillion economic stimulus package and comprehensive COVID relief bill that provides a wide range of assistance to businesses and individuals. As with the COVID-related Acts preceding it, ARPA facilitates much of this assistance through changes to the federal tax code. This blog Continue Reading