Ideas & Insights

The IRS has recently released new draft instructions for schedules K-2 and K-3 for international tax reporting purposes.

Guidance provides procedures to implement the retroactive 30-year ADS recovery period for residential rental property.

Tax bill makes significant changes to rules affecting income taxes, inheritance taxes, credits, bonus depreciation and federal conformity.

IRS concludes that a section 481(a) adjustment retains its character as depreciation when computing a taxpayer’s ATI for section 163(j).

During conversations on Saturday June 5, 2021, the G7 made historic strides toward multilateral agreement on a 15% global minimum tax rate.

Administration issues Presidential priorities and pay-fors. Corporations and wealthy individuals face prospect of increasing tax rates.

Proposals include a $500,000 cap on gain deferral for like-kind exchanges and eliminating stepped-up basis with a $1 million exemption.

Summary of the American Families Plan and the potential impact that it could have on the real estate industry.

Biden’s plan to grow the middle class, expand economic growth and leave the US more competitive, may be funded with tax changes.

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.

IRS modifies guidance on wages that are includible when computing section 199A deduction for taxpayers with short tax years.

Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.

Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.

Final carried interest regulations ease rules for capital interest allocations as well as related party transfers.

New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.

The regulations largely mirror the proposed regulations with additional, mostly favorable, clarifications for taxpayers.

The final regulations broaden the definition of real property compared to the more restrictive definition in the proposed regulations.

The IRS will release proposed regulations confirming the SALT deduction limit will not apply to entity-level taxes imposed on pass-throughs.

For corporations with NOLs that anticipate 2021 income, a change of fiscal year may mitigate the impact of the 80% NOL deduction limitation.