Taxpayers are generally limited in their options for contesting state and local tax matters. The statutes imposing income, corporate, sales and property taxes prescribe the steps to be taken and the forum for challenging those taxes. The doctrine of ‘exhaustion of administrative remedies’ requires taxpayers to go through the administrative procedures before being able to go to court to adjudicate their protests. This year, the U.S. Court of Appeals for the Seventh Circuit opened the…

Greenberg Traurig Global Tax Practice Shareholder G. Michelle Ferreira, who is also co-managing shareholder of the firm’s San Francisco and Silicon Valley offices, is quoted in a Law360 article discussing settlement offers from the IRS for syndicated conservative easement cases. Read the full article, “Careful Evaluation Needed Before Acceptance Of Easement Deals” (subscription required).…

The IRS has announced that lenders should not file tax information returns to report forgiveness of debt on Paycheck Protection Program (PPP) loans. Lenders should take special care with respect to this announcement in order to avoid potential class action claims. Read the full GT Alert, “Lenders Should Not Report PPP Loan Forgiveness to IRS or to Borrowers.”…

On Budget Day, 15 September 2020, the Dutch Ministry of Finance presented its 2021 tax plan. For the proposed bills to have effect, they first must be approved by Parliament. If approved, many of the proposed measures will have effect beginning 1 January 2021, with some beginning 1 January 2022. This GT Alert outlines current proposals and previous measures that are proposed to have effect beginning 1 January 2021. Read the full GT Alert, “…

The Tax Cuts and Jobs Act of 2017 created an important economic development tool, qualified opportunity zones (QOZs), to incentivize private investment in businesses, projects and commercial property in economically distressed communities. Governors from all states, including Minnesota, have now designated areas as QOZs which are eligible for tax-advantages. IRC Sections 1400Z-1 and 1400Z-2 and the related regulations and guidance provide that real estate and other investors can defer current capital gains, increase basis in…

More than 20 attorneys from the Tax Practice and Private Wealth Services Practice of global law firm Greenberg Traurig, LLP were included in the 2021 edition of Best Lawyers in America. In addition, seven attorneys from the firm’s Tax and Private Wealth Services practices are recognized in the inaugural edition of Best Lawyers: Ones to Watch. This year, more than 400 Greenberg Traurig attorneys from across the firm’s U.S. offices are listed in the publication,…

On July 31, 2020, the Department of Treasury and IRS issued proposed regulations that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue Code. Long-term capital gains derived by individuals are subject to a preferential 20% US federal income tax rate (plus 3.8% “net investment income” tax after certain income thresholds are met).  On the other hand, individuals are subject to US federal income tax on short-term capital gains at…