In a recently decided case 3 University Plaza SPE, LLC v. City of Hackensack 5002-2014, 1670-2015, 3553-2016, 1163-2017, 3768-2018, 12891-2019 – 3 University Plaza SPE LLC, et al. v. Hackensack City (njcourts.gov) concerning a large 225,000 square foot class A office building, the Tax Court addressed the valuation community’s on-going debate as to whether certain
Tax
2022 Changes to Estate and Gift Tax Exclusions
The IRS released Revenue Procedure 2021-45 which announces the increase in 2022 of the estate, gift and generation-skipping transfer tax applicable exclusion amounts from $11.7 million to $12.06 million. The applicable exclusion amounts currently remain scheduled to expire on December 31, 2025, which would result in a reduction in the exclusion amounts to $5 million…
“Accidental Americans” Must Pay US Tax on Worldwide Income and Provide Detailed US Tax Reporting
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days.
This frequently happens in an understandable way, and involves a non-US person who has family in the US. The non-US person comes to visit his…
Starting an Active Business in an Opportunity Zone
This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”).
The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage long-term investment in economically distressed communities. The IRS issued two substantive sets of proposed regulations outlining rules for QOZ investments (in…
Carried Interests: Final Capital Gain Recharacterization Rules Released
In the 2017 Tax Act, Congress adopted Code §1061, a provision which affects non-corporate holders of certain carried interests, which the new law refers to as applicable partnership interests (“APIs”). Under the new law, certain long-term capital gains (“LTCGs”) relating to APIs may be recharacterized as short-term capital gains (“STCGs”) unless the gains are from…