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Daniel W Stahl

Daniel W Stahl

October 26, 2011 | New York Law Journal

Tax Court Decision Highlights Passive Loss Rules

In their Taxation column, Ezra Dyckman and Daniel W. Stahl of Roberts & Holland discuss how sa recent ruling provides a reminder of the inner-workings of the passive activity loss rules and the importance of considering the single activity election, as well as provide encouragement since the court declined to impose penalties in a case where it technically could have done so.

By Ezra Dyckman And Daniel W. Stahl

12 minute read

October 24, 2012 | New York Law Journal

Appellate Court Rejects Tax Credit Transaction

In their Taxation column, Roberts & Holland's Ezra Dyckman and Daniel W. Stahl discuss the Third Circuit's holding that reversed the Tax Court's affirmation of the allocation of federal historic rehabilitation tax credits to an investor, and what that rejection means for the ability of real estate developers to engage in tax credit transactions.

By Ezra Dyckman and Daniel W. Stahl

10 minute read

August 22, 2012 | New York Law Journal

Tax Court Addresses Real Estate Cost Segregation

In their Taxation column, Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, review a recent decision which, while affirming the ability of a taxpayer to take depreciation on real estate based on cost segregation, provides a note of caution to real estate owners as to the perils of being over-aggressive in a cost segregation and the importance of having detailed documentation to back it up.

By Ezra Dyckman and Daniel W. Stahl

8 minute read

April 24, 2013 | New York Law Journal

Giving Up Is Hard to Do: Abandonment of Property Rules

In their Taxation column, Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, write that taxpayers who are expecting an ordinary loss from an abandonment may be rudely awakened to the realization that their loss is a capital loss - or that they have no loss at all.

By Ezra Dyckman and Daniel W. Stahl

6 minute read

April 27, 2011 | New York Law Journal

Tax Credit Transaction Found To Have Substance

In their Taxation column, Ezra Dyckman and Daniel W. Stahl of Roberts & Holland discuss the recent Historic Boardwalk Hall, LLC v. Commissioner decision, to weigh the potential pitfalls of Congress' encouragement of the rehabilitation of historic structures by providing that taxpayers could receive federal tax credits by engaging in restoration projects.

By Ezra Dyckman and Daniel W. Stahl

8 minute read

December 23, 2009 | New York Law Journal

Grouping a Rental Activity Under the Passive Loss Rules

Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, write that in a recent case, the United States Tax Court addressed the grouping of activities under the passive loss rules when one of the activities is a rental activity. The case, they say, highlights some of the rules affecting how the passive loss limitations affect real estate owners.

By Ezra Dyckman and Daniel W. Stahl

8 minute read

August 25, 2010 | New York Law Journal

Carried Interest Legislation May Cover More Than You Think

In their Taxation column, Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, write that legislation to limit the favorable tax treatment of "carried interests" covers numerous arrangements involving investment in real estate. Effective tax planning may avoid some undesirable consequences of the proposed legislation.

By Ezra Dyckman and Daniel W. Stahl

10 minute read

December 22, 2010 | New York Law Journal

Series LLC Regulations: Do They Provide Certainty?

In their Taxation column, Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, write that the Treasury Department recently issued Proposed Regulations that address the treatment of a series LLC for federal tax purposes.

By Ezra Dyckman and Daniel W. Stahl

9 minute read

June 22, 2011 | New York Law Journal

Court Recharacterizes Tax Credit Transfers: What Went Wrong?

Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, analyze a recent Fourth Circuit holding that the transfer of state historic rehabilitation tax credits by a partnership to its partners was a disguised sale, and compare that partnership's structure to one whose transfer of federal historic rehabilitation tax credits was respected by the Tax Court.

By Ezra Dyckman and Daniel W. Stahl

9 minute read

June 23, 2010 | New York Law Journal

Recharacterization Rejected In Tax Credit Transaction

In their Taxation column, Ezra Dyckman, a partner at Roberts & Holland, and Daniel W. Stahl, an associate at the firm, write that the Tax Court recently wrestled with what the appropriate characterization of a transaction should be in a situation where investors contributed money to a partnership and received allocations of tax credits.

By Ezra Dyckman and Daniel W. Stahl

5 minute read