Charles S Nelson

February 23, 2021 | New York Law Journal

On July 31, 2020, Treasury released proposed regulations under Section 1061, and on January 7, 2021, Treasury finalized these regulations. The final regulations largely adopt the proposed regulations, but with some important modifications that are largely favorable to taxpayers.

By Ezra Dyckman and Charles S. Nelson

6 minute read

December 22, 2020 | New York Law Journal

On Nov. 26, 2018, the Treasury Department issued proposed regulations under Section 163(j), and on July 28, 2020, these regulations were finalized. The final regulations largely adopt the proposed regulations, but with some important modifications that are generally favorable to taxpayers.

By Ezra Dyckman and Charles S. Nelson

6 minute read

October 20, 2020 | New York Law Journal

In October, 2019, the Treasury Department finalized a set of regulations that will have an important impact on how liabilities are allocated when a partner guarantees partnership debt. In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the importance of the allocation of a partnership's liabilities.

By Ezra Dyckman and Charles S. Nelson

5 minute read

August 25, 2020 | New York Law Journal

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the proposed Treasury regulations under Section 1061 which clarify provisions of the carried interest rules.

By Ezra Dyckman and Charles S. Nelson

5 minute read

April 21, 2020 | New York Law Journal

On March 27, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law. The Act includes many provisions aimed at mitigating the economic impact of the coronavirus outbreak, such as cash rebates to individuals and loans and tax credits to businesses. However, the Act also contains several modifications and technical corrections to the 2017 Tax Cuts and Jobs Act that could significantly benefit real estate owners.

By Ezra Dyckman and Charles S. Nelson

5 minute read

October 22, 2019 | New York Law Journal

In their Taxation column, Ezra Dyckman and Charles Nelson discuss 'Lipnick v. Commissioner,' a recent opinion issued by the U.S. Tax Court which clarifies how the interest characterization rules work in the context of partnerships that have made debt-financed distributions to their partners.

By Ezra Dyckman and Charles S. Nelson

5 minute read

August 27, 2019 | New York Law Journal

There are a number of approaches for owners of rental real estate to monetize low-basis real estate while maintaining tax deferral. One method that can achieve these objectives is a long-term lease with a large initial payment of rent. Section 467 of the Internal Revenue Code generally governs the income tax treatment of leases with prepaid rent. In their Taxation column, Ezra Dyckman and Charles Nelson discuss the pros and cons of Section 467.

By Ezra Dyckman and Charles S. Nelson

5 minute read

February 26, 2019 | New York Law Journal

In their Taxation column, Ezra Dyckman and Charles Nelson discuss the proposed Treasury Department regulations implementing Section 163(j) of the Internal Revenue Code which was amended to place a limit on business interest deductions.

By Ezra Dyckman and Charles S. Nelson

5 minute read

October 23, 2018 | New York Law Journal

On Aug. 16, the Treasury Department issued proposed regulations, under Section 199A of the Internal Revenue Code, which generally allows a 20 percent deduction on income from pass-through entities. The legislation left a lot of uncertainty regarding many issues, and the proposed regulations provide some clarity. 

By Ezra Dyckman and Charles S. Nelson

6 minute read

August 21, 2018 | New York Law Journal

In their Taxation column, Ezra Dyckman and Charles S. Nelson discuss proposed Treasury Department regulations that would once again permit transactions in which a partner can contribute property to a partnership and receive a tax-free distribution of money.

By Ezra Dyckman and Charles S. Nelson

6 minute read