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Legacy Advisors

Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

By Michelle Ferreira, Barbara T. Kaplan & Jennifer A. Vincent

November 14, 2019

While the IRS has been cracking down on syndicated conservation easements for over ten years, earlier this year Chuck Rettig, the Commissioner of the IRS, announced several campaign areas upon which the IRS would heighten focus in the coming year. Following through on this promise, on Nov. 12, 2019, the IRS announced a significant increase in enforcement actions for syndicated conservation easements in Issue Number IR-2019-182. This GT Alert explains what a syndicated conservation…

Legacy Advisors

New York Issues Sales Tax Guidance for Businesses With No Physical Presence in the State

By Glenn Newman

November 8, 2019

In South Dakota v. Wayfair, Inc., et al., 138 S. Ct. 2080 (decided June 21, 2018), the Supreme Court of the United States held that physical presence in a state was not necessary for retailers to be required to collect and remit state sales and use tax. Many states, including New York, have passed statutes implementing that decision. On Nov. 5, 2019, the New York State Department of Taxation and Finance issued TSB-M-19(4)S, providing guidance…

Legacy Advisors

Greenberg Traurig Amsterdam advises InterXion on its USD 8.4 Billion Combination with Digital Realty

By Greenberg Traurig

October 31, 2019

The Amsterdam office of global law firm Greenberg Traurig, LLP represented InterXion (NYSE: INXN), a leading European provider of cloud- and carrier-neutral colocation data center services, in a business combination with Digital Realty (NYSE: DLR). The transaction values InterXion at approximately USD 93.48 per share or USD 8.4 billion of total enterprise value in an all-stock deal, based on Digital Realty’s closing price on Monday. This strategic transaction is the largest in the history of the…

Legacy Advisors

IRS Issues New Cryptocurrency Guidance

By Mary F. Voce & Pallav Raghuvanshi

October 10, 2019

On Oct. 9, 2019, the Internal Revenue Service (IRS) released revenue ruling (Rev. Rul. 2019-24) and a Frequently Asked Questions (FAQs) document, which provide additional guidance on the tax treatment and reporting obligations for transactions involving virtual currency (also known as cryptocurrency). This guidance supplements the original guidance that was issued in 2014 in the form of a notice (Notice 2014-21), which provides a baseline rule that cryptocurrency is property for federal income tax purposes.…

Legacy Advisors

Greenberg Traurig Sponsors 2019 Samsung Gives Charity Gala

By Greenberg Traurig

September 22, 2019

Greenberg Traurig recently sponsored the 2019 Samsung Gives Charity Gala in New York City. With hundreds of guests in attendance, including musicians, athletes, and celebrities, this program is dedicated to celebrating worthy causes, furthering community impact, and honoring organizations and the people who work so hard every single day to make the world a better place. For more events-related posts, click here.…

Legacy Advisors

IRS Offers Settlements to Some Micro-Captive Insurance Taxpayers

By Barbara T. Kaplan & Josh Prywes

September 20, 2019

On Sept. 16, 2019, the IRS announced it is offering settlements to certain taxpayers with open audits of micro-captive insurance transactions. The IRS has targeted these micro-captive insurance transactions since 2014, and they were designated as transactions of interest in 2016.1 Although micro-captive insurance transactions have gained popularity among closely held entities, the IRS has challenged such transactions as abusive, stating that they “are inconsistent with arm’s length transactions and sound business practices.”…

Legacy Advisors

Applicable Federal Rates and Code Section 7520 Rate for October 2019 – Downward Trend Accelerates

By Carmen Irizarry-Diaz

September 18, 2019

The Internal Revenue Service (IRS) publishes monthly the applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and the Code Section 7520 rate (7520 rate) for the month following the month in which the Revenue Ruling is published in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the AFRs and 7520 rate for the following month provides a window of opportunity for the immediate or…

Legacy Advisors

Retailers Not Eligible for 100% Leasehold Improvement Write-Off Due to Legislative Glitch

By Marvin A. Kirsner

September 18, 2019

The 2017 Tax Cuts and Jobs Act provided a 100% first year write-off for many types of capital expenditures. Congressional tax writers intended this benefit to be available for leasehold improvements, which would be a boon to retail and restaurant businesses and their landlords. Unfortunately, in the rush to get the tax bill pushed through, there was a legislative drafting error that caused leasehold improvements to be left out of the definition of expenditures eligible…

Legacy Advisors

Applicable Federal Rates and Code Section 7520 Rate for September 2019 – Downward Trend Continues

By Carmen Irizarry-Diaz

September 17, 2019

Legacy Advisors

IRS Aims to Catch Up to Tech Advancements

By Erez I. Tucner & Pallav Raghuvanshi

September 10, 2019

Recently proposed IRS regulations would significantly affect tax on income from international cloud transactions and electronic transfers of digital content. Accordingly, CFOs should review the structure of agreements involving such transactions and transfers. Issued on Aug. 9, the proposed regulations represent an attempt by the IRS to catch up with technological advancements, two decades after it issued regulations addressing the U.S. federal income tax treatment of cross-border transfers of computer programs. Click here to read …

Legacy Advisors

Powered by GT Tax - A Greenberg Traurig Knowledge Product

Blog Authors

Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

New York Issues Sales Tax Guidance for Businesses With No Physical Presence in the State

Greenberg Traurig Amsterdam advises InterXion on its USD 8.4 Billion Combination with Digital Realty

IRS Issues New Cryptocurrency Guidance

Greenberg Traurig Sponsors 2019 Samsung Gives Charity Gala

IRS Offers Settlements to Some Micro-Captive Insurance Taxpayers

Applicable Federal Rates and Code Section 7520 Rate for October 2019 – Downward Trend Accelerates

Retailers Not Eligible for 100% Leasehold Improvement Write-Off Due to Legislative Glitch

Applicable Federal Rates and Code Section 7520 Rate for September 2019 – Downward Trend Continues

IRS Aims to Catch Up to Tech Advancements

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