January 2018

2018 Real Estate Tax Abatement Process

Tax abatement season is here, with some fast approaching filing deadlines in Connecticut, Massachusetts, New Hampshire, and Rhode Island. If you have not already done so, now is the time for property owners to review their real estate tax assessments to de…

November 2016

Final Treasury Regulations under Section 385 Released to Prevent Earnings-Stripping and Reclassify Debt as Equity

Since the advent of the US Income Tax Code, the question of whether an interest constitutes debt or equity for US tax purposes has been the source of debate. Amid great concern and criticism, the Treasury Department published final regulations under Sectio…

April 2016

Real Estate & Tax Update: IRS Reverses Course on Partnership Tax Implications of Bad Boy Guarantees

Real estate investors will be relieved to know that the Internal Revenue Service (IRS) has reversed course on a controversial position.In our March client alert,[1] we reported that the IRS released Chief Counsel Advice (CCA) 201606027[2] on February 5,…

New Partnership Audit Procedures Create Uncertainty around Partnership Agreements

Every business in partnership form is affected by the recent signing[1] of the Bipartisan Budget Act of 2015 (the “Budget Act”) and should re-examine the tax provisions of its partnership agreements.Revenue Service (IRS) for all entities treated as …

March 2016

IRS Advice on Bad Boy Guarantees Should Concern Real Estate Investors

The Internal Revenue Service (IRS) recently published advice that raises concerns for investors in real estate partnerships1. The published advice changes the tax implications for investing partners when a partnership’s real estate financing document inc…

August 2015

Highway Funding Bill Brings Important Tax Changes

Among the important tax provisions of HR 3236 are the following.Certain US persons with foreign financial accounts are required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). The FBAR form originated under the Bank Secrecy A…