Final Regs Defining ‘Real Property’ for Section 1031: IRS Gets It Right With ‘State Law Plus’
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’ Continue Reading …
Opportunity Zones: Further Extensions in the Land of Oz
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 Continue Reading …
Section 199A, SSTBs and Related Parties
Introduction. The Tax Cuts and Jobs Act of 2017 (the “Act”) added Section 199A to the Internal Revenue Code (the “Code”). Section 199A provides a deduction that reduces the effective tax rate on qualified business income (“QBI”) for owners of businesses taxed as sole proprietorships, partnerships, limited partnerships, limited liability Continue Reading …
The Long Arm of California’s Franchise Tax Board
In two recent decisions, both of which will be precedential, the California Office of Tax Appeals (OTA) ruled against taxpayers and in favor of the California Franchise Tax Board (FTB), as the FTB demonstrated its long reach when it comes to collecting taxes.
In its opinion in The Matter of the Continue Reading …
Section 1202 Qualified Small Business Stock Benefits Revisited
As we make it through 2020 and into 2021, one should consider revisiting the choice of entity in ascertaining which type of business entity is the best entity for a client’s particular needs. Historically, flow-through entities such as partnerships, limited liability companies and S corporations have prevailed over C corporations. Continue Reading …