Business & Tax Blog

We have discussed a structuring technique real estate investors use to protect the lower-federal-income-tax-rate-long-term-capital-gain treatment of real estate gains, before property is converted to an active development purpose that creates higher-tax-rate income. The structuring requires property transfers and the use of multiple business entities, which decreases transparency for the government…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of–money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2014: Short Term AFR…

Governor Rick Scott recently signed legislation providing for three separate sales tax holidays in 2014 for purchases of hurricane supplies, school supplies, and energy-efficient appliances. The sales tax holiday for hurricane supplies runs from May 31 through June 8, 2014, and covers (a) portable self-powered light sources selling for $20…

In January we noted a new Tax Court case, Pool v. Commissioner, addressing the boundaries of a structuring technique real estate investors use to protect the lower-federal-income-tax-rate-long-term-capital-gain treatment of real estate gains, before property is converted to an active development purpose that creates higher-tax-rate income. Tax Court Sets Boundaries For Predevelopment Capital…

On April 3, 2014, the Senate Finance Committee favorably reported out of Committee the “Expiring Provisions Improvement Reform and Efficiency Act.” The Act has bipartisan Senate Finance Committee support, but it is uncertain when and how the House Ways and Means Committee will deal with the subject. The Act would…