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Search Results : Taxation

High-Tech Start-Ups Get Relief From Latest Opportunity Zone Proposed Treasury Regulations

April 18, 2019
Mark Wisniewski  |  Opportunity Zone, Taxation

Qualified Opportunity Zones (“QOZs”) are low-income population census tracts situated in urban, suburban or rural areas that have been specifically designated as QOZs by the governors of the various states and U.S. territories in which such QOZs are situated, and certified as such by the U.S. Treasury.[…]

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Disclosure of Special Taxing Districts

March 21, 2019
Jeffrey R. Margolis  |  Taxation, Real Estate

My January 23, 2019 post explained that Miami-Dade County was considering an amendment to the Code of Miami-Dade County relating to the disclosures required by a seller of residential property located within a special taxing district. […]

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Miami-Dade County to Consider Ordinance Requiring Disclosure of Special Taxing Districts

January 23, 2019
Jeffrey R. Margolis  |  Real Estate, Residential Real Estate, Taxation

Miami-Dade Board of County Commissioners will consider today for first reading an amendment to the Miami-Dade County Code which would require sellers of residential property located within a special taxing district to disclose to buyers that such property is located within a special taxing district and subject to payment of assessments.[…]

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Assessing Mixed-Use Projects in Florida in 2019

December 12, 2018
Barry D. Lapides  |  Real Estate, Taxation

The desire for live, work and play lifestyles is not slowing down in Florida as major mixed-use projects are continuing to be developed throughout the state, from Miami Worldcenter to the Cascades Project in Tallahassee. However, the popularity of these mixed-use projects has created a legal conundrum.[…]

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Tax Breaks for Investment in Opportunity Zones – Proposed Treasury Regulations

October 30, 2018
Bryan S. Appel and Mark Wisniewski  |  Taxation, Opportunity Zone

On Friday, October 19, 2018, the Internal Revenue Service (the “IRS”) released the eagerly anticipated qualified opportunity zone (“O-Zones”) Proposed Treasury Regulations (the “Proposed Regulations”) relating to qualified opportunity funds (“O-Zone Funds”). O-Zone Funds are investment vehicles created by the Tax Cuts and Jobs Act that provide taxpayers, with eligible capital gains, an opportunity[…]

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Tax Aspects of Qualified Opportunity Zone Funds – A Prequel

August 29, 2018
Mark Wisniewski and Bryan S. Appel  |  Taxation, Opportunity Zone

The Tax Cuts and Jobs Act of 2017 (the “Act”), signed into law by President Trump on December 22, 2017, created a series of new tax incentives for taxpayers willing to make long-term investments in certain qualified low-income population census tracts designated by the Governors of each State and certified by the U.S. Treasury as “qualified opportunity[…]

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Impact of Tax Reform Act on Parties to Litigation

April 2, 2018
Mark Wisniewski  |  Corporate, Tax Litigation, Taxation

As a result of the new tax reform act (H.R. 1), signed into law by President Trump on December 22, 2017, a below-the-line deduction[1] for legal fees incurred in litigation is no longer available for tax years 2018 through 2025. Thus, plaintiffs in numerous categories of litigation could end up paying taxes on one hundred percent (100%) of the gross[…]

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The New Deduction for Pass-Through Entities and Sole Proprietorships

January 22, 2018
Mitchell W. Goldberg, Mark Wisniewski, and Nick Jovanovich  |  Corporate, Taxation

The new tax reform act (H.R. 1), signed into law by President Trump on December 22, 2017, added a new provision to the tax code (i.e., IRC Section 199A), for taxable years beginning after 2017 and before January 1, 2026, which allows taxpayers other than corporations to deduct 20% of their allocable share of qualified business income from pass-through[…]

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Tax Court Giveth and Congress Taketh Away: Taxation of Sale of U.S. Partnership Interests by Foreign Persons and Impact on M&A Transactions

January 16, 2018
Mitchell W. Goldberg  |  Corporate, Mergers & Acquisitions, Taxation

The Tax Cuts and Jobs Act (H.R. 1) (the “Act”), signed by President Trump on December 22, 2017, implemented the most comprehensive overhall of the Internal Revenue Code of 1986, as amended (the “Code”) in decades. In particular, the Act overturned a 2017 Tax Court case, Grecian Magnesite Mining, Indus. & Shipping Co. v. Commissioner, 149 T.C.[…]

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Highlights of H.R. 1 (The “Tax Bill”), Formerly Known as the “Tax Cuts and Jobs Act,” Passed by Congress and Signed by the President

December 26, 2017
Mark Wisniewski  |  Corporate, Tax Litigation, Taxation

On December 22, 2017, the President signed into law the tax bill, an extremely broad and all-encompassing piece of tax reform legislation. the following is a brief synopsis in tabular format of select key provisions contained in the tax bill which generally go into effect on January 1, 2018:Tax Reform for Individuals TOPIC THE TAX[…]

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U.S. Taxation of Convertible Virtual Currency - It Is Not a Myth!

November 29, 2017
Mark Wisniewski  |  Bitcoin, Taxation

There is a pervasive myth that virtual currency exists in a regulatory vacuum – but the Internal Revenue Service (the “IRS”), the U.S. Securities and Exchange Commission (the “SEC”), the U.S. Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading Commission, and multiple state legislatures and regulators (e.g., blue sky laws, money[…]

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