Early on in her tenure at the White House, Knight reportedly butt heads with Treasury Secretary Steve Mnuchin over what
kind of tax structure that US should have.
Not exact matches
It'll be interesting if the Republicans face the
kind of blowback that the Trudeau government did; while the plan technically cuts the taxation rate on such «pass - through»
structures, it has the potential to actually raise
taxes for a sizeable proportion
of those companies:
Our investment management practice advises on investment funds,
tax law and regulatory issues in the context
of structuring various
kinds of collective capital assets investing in private equity, real estate, renewable energy, leasing agreements and other asset classes.
Later, once your business is humming along, you'll want to look at
tax in more detail, and also at what
kind of business
structure is best for your situation: see a lawyer.
A lot
of financial plans demand that the right
kind of capital gains
tax efficiency is also built into the
structure.
Legally, in order for the
tax - exempt status
of a bond to pass through any
kind of structured product, the credit risk
of the municipal has to be retained by the investor.
Working seamlessly with our
Tax Practice Group, we counsel clients on all tax aspects of their real estate deals, including structuring like - kind exchanges of real esta
Tax Practice Group, we counsel clients on all
tax aspects of their real estate deals, including structuring like - kind exchanges of real esta
tax aspects
of their real estate deals, including
structuring like -
kind exchanges
of real estate.
Then ask yourself if Don in the corner office
of your firm who bills 2200 hours a year
structuring international
tax treaties has the time, aptitude, experience and mindset to do that
kind of thinking.
In this type
of tax - deferred like -
kind Exchange, the Investor can build a new
structure, improve an existing
structure or retrofit the property before selling their relinquished property.
This
structure provides the Investor with a great deal more flexibility in planning the acquisition and financing
of the like -
kind replacement property because the actual
tax - deferred like -
kind Exchange has not yet occurred.
The issuance
of Revenue Procedure 2000 - 37 gave Investors and Qualified Intermediaries guidelines on how to
structure reverse
tax - deferred like -
kind exchange transactions where the Investor's like -
kind replacement property can be acquired before he disposes
of his relinquished property.
The term Reverse Exchange is therefore really a misnomer because it actually consists
of: (1) a parking transaction where either the replacement property or the relinquished property is acquired and held or parked by the Exchange Accommodation Titleholder; and (2) a simultaneous
tax - deferred like -
kind Exchange (not a true Reverse Exchange) occurs either at the beginning (Exchange First
Structure) or at the end (Exchange Last
Structure)
of the Reverse Exchange transaction.
The Exchange Last parking
structure is the only one
of the two that would allow the Exchange Accommodation Titleholder to contribute additional cash if the equity from the relinquished property is more than the down payment on the like -
kind replacement property to avoid a
tax liability.
In order to defer 100 %
of the applicable depreciation recapture and capital gain income
tax liabilities, Investors must meet three requirements when
structuring tax - deferred like -
kind Exchanges: (1) Exchange or trade equal or up in value; and (2) reinvest 100 %
of the Investors equity (net cash proceeds from sale
of relinquished property); and (3) replace any debt with new debt on the replacement property.
Section 1031
of the Internal Revenue Code allows taxpayers who properly
structure their transactions through a qualified intermediary to defer and potentially eliminate the income
tax (i.e. Capital Gains, Depreciation Recapture) that would otherwise be due from the sale
of property held for productive use in their trade or business or investment, when they purchase other «like -
kind» property.
Her areas
of federal income
tax practice include advising on the
structuring and unwinding
of partnerships and joint ventures; the taxation
of partnership operations; REIT
tax compliance and due diligence; like -
kind exchange planning; and general
tax accounting for real estate entities and operations.
1031 Exchange: The sale or disposition
of real estate or personal property (relinquished property) and the acquisition
of like -
kind qualified use real estate or personal property (replacement property) in a transaction
structured as a
tax - deferred, like -
kind exchange pursuant to Section 1031
of the Internal Revenue Code and Section 1.1031
of the Treasury Regulations.
Improvement Exchange: A
tax - deferred, like -
kind exchange whereby the Qualified Intermediary and / or Exchange Accommodation Titleholder acquires title and holds title to the replacement property on behalf
of Investor, during which time new or additional
structures or improvements are constructed or installed on or within the replacement property.
Also known as a «like -
kind» exchange, a 1031 exchange is a way
of structuring the sale
of an asset so that the seller's profit or gain is not currently
taxed.
Exchange: The sale or disposition
of real estate or personal property (relinquished property) and the acquisition
of like -
kind real estate or personal property (replacement property)
structured as a
tax - deferred, like -
kind exchange transaction pursuant to Section 1031
of the Internal Revenue Code and Section 1.1031
of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture
taxes.
2) We prepare all
of the legal documents necessary to
structure your 1031 exchange transaction, including the
Tax - Deferred Exchange Agreement, the Assignment, Acceptance, Notice and Direction to Convey and any other transactional documents necessary to complete your tax - deferred like - kind exchange transacti
Tax - Deferred Exchange Agreement, the Assignment, Acceptance, Notice and Direction to Convey and any other transactional documents necessary to complete your
tax - deferred like - kind exchange transacti
tax - deferred like -
kind exchange transaction.
Real Property Exchange: The sale or disposition
of real estate (relinquished property) and the acquisition
of like -
kind real estate (replacement property)
structured as a
tax - deferred, like -
kind exchange transaction pursuant to Section 1031
of the Internal Revenue Code and Section 1.1031
of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture
taxes.
Like -
Kind Exchange: The sale or disposition of real estate or personal property (relinquished property) and the acquisition of like - kind real estate or personal property (replacement property) structured as a tax - deferred, like - kind exchange transaction pursuant to Section 1031 of the Internal Revenue Code and Section 1.1031 of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture ta
Kind Exchange: The sale or disposition
of real estate or personal property (relinquished property) and the acquisition
of like -
kind real estate or personal property (replacement property) structured as a tax - deferred, like - kind exchange transaction pursuant to Section 1031 of the Internal Revenue Code and Section 1.1031 of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture ta
kind real estate or personal property (replacement property)
structured as a
tax - deferred, like -
kind exchange transaction pursuant to Section 1031 of the Internal Revenue Code and Section 1.1031 of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture ta
kind exchange transaction pursuant to Section 1031
of the Internal Revenue Code and Section 1.1031
of the Treasury Regulations in order to defer Federal, and in most cases state, capital gain and depreciation recapture
taxes.