A new Internal Revenue Service (IRS) Private Letter Ruling says that transferable development rights (TDRs) are of “like kind” with tangible real property and eligible for 1031 tax deferred treatment, even though these rights are intangible rights related to real
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Treasury and IRS Issue New Proposed Regulations on Digital Assets
On Aug. 25, 2023, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations (the Proposed Regulations) regarding the sales or exchanges of digital assets, including cryptocurrency. The Proposed Regulations relate to both information reporting requirements…
Guidance Published on Florida’s Live Local Act Property Tax Exemption for Middle Market Multifamily Projects
This past legislative session, the Florida legislature passed the Live Local Act, a comprehensive affordable housing law incentivizing private developers to build multifamily residential projects and to rent apartments at rates affordable to middle income families. See April 2023 GT Alert…
IRS Clarifies Taxation of Staking Crypto Rewards
To address the tax implications for taxpayers who stake cryptocurrency on a proof-of-stake blockchain and receive validation rewards, on July 21 the Internal Revenue Service (IRS) issued Revenue Ruling 2023-14.
IRS Says General Supply Chain Disruptions Do Not Justify Employee Retention Credit
The IRS Office of Chief Counsel has published a general legal memo clarifying prior guidance to confirm that general supply chain disruptions alone do not justify a claim for the employee retention credit (ERC) under the Coronavirus Aid, Relief, and…
Proposed Regulations under Section 6418 Transferability of Clean Energy Tax Credits
On June 14, 2023, the IRS released proposed and temporary regulations and additional guidance describing rules for eligible taxpayers to benefit from clean energy projects through selling any of the 11 eligible U.S. federal income tax credits to an unrelated…
Proposed Regulations under Section 6417 Direct Pay for Clean Energy Tax Credits
On June 14, 2023, the IRS released proposed and temporary regulations and additional guidance describing rules for applicable taxpayers to benefit from clean energy projects through electing to receive direct payment for the amount of the 12 applicable U.S. federal…
New York State Changes the Rules on Tax Appeals
Now that the New York State legislature has ended its session, we can examine one piece of legislation that changed the landscape for tax appeals challenging the assessment by the New York State Department of Taxation & Finance (DT&F) of…
IRS Releases Guidance on Elective Payments and Transferability of Certain Tax Credits
On June 14, 2023, the IRS released proposed regulations and additional guidance describing rules for applicable taxpayers to benefit from investments in renewable energy projects through a direct payment of the tax credit amount or by transferring (i.e., selling) the…
IRS Provides Additional Guidance for Advanced Energy Projects Under Section 48C of the Code
On May 31, 2023, the IRS released Notice 2023-44, which provides additional guidance for applicants seeking allocations of the Qualifying Advanced Energy Project Credit under Section 48C of the Internal Revenue Code (a “Section 48C credit”). The Section 48C…