Insights

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…

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 May 2014: Short Term AFR…

Foreigners, especially Canadians, continue to comprise a significant percentage of Florida real estate purchases. The National Association of Realtors reported that during the recent 12-month period ending July 2013 the total sales volume of Florida residential real estate purchases by foreigners was $6.4 billion (9% of total Florida residential sales volume)….

We have previously written about a one-time income tax election opportunity that could permanently reduce your exposure to the Obamacare 3.8% Surtax. As tax-filing season comes a to a close, this is a final reminder that you must make the election on your first income tax return that implicates the…