Ezra Dyckman

December 23, 2009 | New York Law Journal

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

February 27, 2008 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate at the firm, write that the recently enacted Mortgage Forgiveness Debt Relief Act of 2007, in addition to the forgiveness of debt provisions suggested by its title, contains an important new rule that is extremely favorable to cooperative housing corporations. The new legislation is effective for taxable years ending after Dec. 20, 2007, which means that the new rules apply for 2007 calendar year taxpayers.

By Ezra Dyckman and Seth Hagen

8 minute read

December 22, 2004 | New York Law Journal

Ezra Dyckman and Ronald A. Morris, members of Roberts & Holland, write that President Bush promised major tax reform during his second term. In light of the complexity and far reaching nature of relatively narrow changes now in place, which are keeping Treasury, the IRS and tax practitioners fully occupied, one can only imagine what lies in store.

By Ezra Dyckman and Ronald A. Morris

10 minute read

April 25, 2007 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, and Seth Hagen, an associate at the firm, write that a recent private letter ruling from the IRS holds that a successor entity treated as a different taxpayer than its predecessor entity may be treated as a continuation of the predecessor entity for purposes of analyzing the holding purpose requirement of section 1031, a significant step forward for the IRS in this area.

By Ezra Dyckman and Seth Hagen

11 minute read

August 25, 2010 | New York Law Journal

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

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

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

April 28, 2010 | New York Law Journal

Ezra Dyckman is a member of Roberts & Holland, and Libin Zhang, an associate with the firm, write: Energy independence is a major American policy goal, and the Internal Revenue Code has not been neglected in that push. One area of growing interest to commercial rental property owners is the business tax credit for purchases of solar panels and other solar energy property.

By Ezra Dyckman and Libin Zhang

6 minute read

October 25, 2006 | New York Law Journal

Ezra Dyckman, a member of Roberts & Holland, writes that while private letter rulings are not precedential, they are usually a good barometer of current IRS thinking. One recent ruling may give hope to investors seeking to execute like-kind exchanges involving New York co-op apartments.

By Ezra Dyckman

6 minute read

June 23, 2010 | New York Law Journal

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