On December 19, 2019, two years after the federal Qualified Opportunity Zone (QOZ) program was enacted, the Treasury Department released final regulations providing guidance on how to apply the rules under this program.
As part of general federal tax reform in 2017, Congress enacted a provision that required tax-exempt organizations to pay tax on certain amounts paid or incurred for employee parking (the Parking Tax).
New rules effective for partnership taxable years beginning after December 31, 2017 dramatically alter the rights and obligations of partnerships (including LLCs treated as partnerships for tax purposes) and partners, in connection with IRS partnership audits and resulting tax assessments.
The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) updated the list of designated Qualified Opportunity Zones on their website to include the designation of 320 Qualified Opportunity Zones in the state of Ohio, as well as additional Qualified Opportunity Zones in Alabama, Delaware, Missouri, Texas and the Northern Marianas Islands.
As part of federal tax reform, Congress created a new program to encourage investment in businesses that are located in low-income communities that are designated as “Qualified Opportunity Zones.” This program creates a new potential source of capital for businesses and real estate developments located in Qualified Opportunity Zones, while at the same time creating a new tax benefit for investors seeking to reduce their tax burden on taxable asset dispositions.
Beginning in 2018, an individual taxpayer generally may deduct 20% of his or her share of “qualified business income” from a U.S. trade or business operated through a partnership (including an LLC treated as a partnership for federal income tax purposes), S corporation, or sole proprietorship (including an LLC treated as a disregarded entity for federal income tax purposes) (the QBI Deduction).
The Tax Cuts and Jobs Act (the “Act”) was signed into law on December 22. The Act brings about immediate, sweeping changes to the federal income tax laws, affecting businesses and business owners across all industries. Most provisions of the Act are effective for taxable years beginning after December 31, 2017. Certain provisions, however, are retroactive to September or November of 2017.
Joseph Mann, a partner in the Vorys Columbus office and a member of the tax group, authored an article for the OOGA Bulletin (the monthly publication of the Ohio Oil and Gas Association) titled “IRS Announces that Marginal Well Production Credits are Available for 2016 Natural Gas Production.”
Joseph Mann, a partner in the Vorys Columbus office and a member of the tax group, authored an article for the OOGA Bulletin titled "Enhanced Oil Recovery Credits and Marginal Well Production Credits: Potential Availability for 2016."
On November 1, 2016, the Internal Revenue Service (IRS) issued Notice 2016-66. The Notice designates certain so-called “micro-captive” insurance company transactions as “transactions of interest” for purposes of Treas. Reg. Sec. 1.6011-4(b)(6), Code Sec. 6111, and Code Sec. 6112.