October 26, 2011 | New York Law Journal
Tax Court Decision Highlights Passive Loss RulesIn 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 TransactionIn 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 SegregationIn 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 RulesIn 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 SubstanceIn 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 RulesEzra 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 ThinkIn 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 TransactionIn 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
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