On April 9, 2020, the IRS extended certain additional key tax deadlines affecting payments from both individuals and businesses due to the impact of the COVID-19 pandemic. Notice 2020-23 expanded upon prior IRS guidance that extended the dates for taxpayers to file Federal tax returns and render tax payments by creating a general extension to
IRS
Court Finds that Penalty for Late Filing of Estate Tax Return Was Arbitrary and Capricious
Seasoned trusts and estates practitioners know certain truths, such as:
- Stuff happens.
- Some estate tax disputes should not be litigated, but they are anyway.
- Sometimes justice is done.
The recent case of Estate of Skeba (Civil Action No 17-cv-10231, D NJ Oct 3, 2019)) in the District Court of New Jersey reflects all of the…
Code §962 Election is an Option for GILTI Planning
The 2017 Tax Act added a new tax on US shareholders of controlled foreign corporations (“CFCs”), the tax on Global Intangible Low-Taxed Income (“GILTI”). GILTI often includes active business income and thus has a widespread impact.
For US C corporations, the regular 21% tax is reduced by a 50% deduction, which lowers the tax rate…
Proposed Regulations Clarify Rules for Qualified Opportunity Zone Planning
Last week, the IRS released proposed regulations regarding investing in Qualified Opportunity Funds (“QOFs”). Click here for a summary of the QOF regime that was enacted as part of the 2017 Tax Cuts and Jobs Act. The proposed regulations generally address three topics:
- The requirements for deferring gain recognition by investing in a QOF;
- Rules
…
Revenue Ruling 2018-29 Addresses Real Estate Investment in Qualified Opportunity Zones
On October 19, 2018, the IRS released Revenue Ruling 2018-29, an eagerly awaited ruling addressing real estate investment in Qualified Opportunity Zones (“QOZs”). In brief, the Revenue Ruling holds that, for purposes of measuring whether a real estate investment is “substantially improved” so that it will qualify as “QOZ business property” and therefore will qualify…