Charles S Nelson

October 22, 2024 | New York Law Journal

In December 2022, the IRS issued proposed regulations designating certain syndicated conservation easements as listed transactions. In their financing column, Ezra Dyckman and Charles Nelson offer their thoughts on how the regulations, finalized by the IRS on Oct. 8, 2024, "seem to go beyond congressional intent and create the added confusion of having two similar but not identical sets of rules."  

By Ezra Dyckman and Charles S. Nelson

5 minute read

August 27, 2024 | New York Law Journal

On June 17, 2024, the IRS released Notice 2024-54, which states that the IRS and the Treasury Department intend to issue proposed regulations relating to partnership basis adjustments resulting from transactions between related parties. The proposed regulations would introduce massive additional complexity to an area of the tax law that is already complicated.

By Ezra Dyckman and Charles S. Nelson

6 minute read

April 23, 2024 | New York Law Journal

In their Financing column, Ezra Dyckman and Charles Nelson discuss the recent Tax Court case, Valley Park Ranch, LLC v. Commissioner, which "is significant because it illustrates the Tax Court's willingness to invalidate a longstanding regulation based on procedural flaws that occurred almost 40 years ago."

By Ezra Dyckman and Charles S. Nelson

5 minute read

February 27, 2024 | New York Law Journal

Whether an LLC is treated as a partnership or a disregarded entity for federal income tax purposes can sometimes have a significant effect on the tax consequences of a transaction. A recent order issued by the Tax Court in Joint Star Properties, LLC v. Commissioner illustrates the sorts of issues that can arise.

By Ezra Dyckman and Charles S. Nelson

6 minute read

December 26, 2023 | New York Law Journal

Ezra Dyckman and Charles Nelson discuss the Inflation Reduction Act, which has expanded the scope of green energy tax credits, and also proposed regulations by the Treasury Department that have the potential to allow even taxpayers with no income tax liability to more easily monetize some of these tax credits.

By Ezra Dyckman and Charles S. Nelson

5 minute read

October 24, 2023 | New York Law Journal

The federal income tax treatment of interest deductions is often complex and unintuitive. A recent Tax Court case, Cardulla v. Commissioner, addressed a number of issues that may be relevant for taxpayers with interest expense on debt attributable to real estate activities.

By Ezra Dyckman and Charles S. Nelson

6 minute read

August 22, 2023 | New York Law Journal

The distinction between COD income and gain on the sale of property was at issue in a recent Tax Court case, Parker v. Commissioner, discussed here.

By Ezra Dyckman and Charles S. Nelson

4 minute read

June 27, 2023 | New York Law Journal

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the recent case, 'ES NPA Holding, LLC v. Commissioner,' where the Tax Court interpreted Revenue Procedure 93-27 favorably. The case showed that taxpayers receiving partnership profits interests should be careful to ensure that they have satisfied all requirements of the revenue procedure.

By Ezra Dyckman and Charles S. Nelson

5 minute read

April 25, 2023 | New York Law Journal

The enactment of the new conservation easement law adds further restrictions to an area of the tax law that was already rife with potential pitfalls. But on the positive side, the new IRS safe harbor language provides some taxpayers who may have deficient conservation easements with a unique but short-lived opportunity to correct those mistakes.

By Ezra Dyckman and Charles S. Nelson

5 minute read

February 21, 2023 | New York Law Journal

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the recently issued Revenue Procedure 2023-9, in which the IRS provides an optional safe harbor method for developers to account for certain common improvement costs of real estate projects.

By Ezra Dyckman and Charles S. Nelson

5 minute read