IRS Notice 2021-10 Provides Additional Short-term Relief For Qualified Opportunity Fund Requirements

As a result of the continuing COVID-19 impact on businesses and individuals the IRS released a second Notice (IRS Notice 2021-10) on January 19, 2021 to provide Opportunity Zone (OZ) investors with additional time to roll capital gains into a Qualified Opportunity Fund (QOF), as well as additional time to make “substantial improvements” to acquired property and additional time to acquire Qualified Opportunity Zone Business Property (QOZBP).  This Notice follows the June 2020 Notice 2020-39 which extended various 2019 and 2020 OZ Program deadlines and testing dates – generally through December 31st. The extended relief under 2021-10 is generally through March 31, 2021.

Details of the relief given by Notice 2021-10 are outlined below:

  • 180-day investment period.Previously, Notice 2020-39 had postponed the investment period to December 31, 2020. Notice 2021-10 further postpones the last day of the 180-day investment period to March 31, 2021, if the last day of the original 180-day investment period fell on or after April 1, 2020

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IRS Notice 2021-10 Provides Additional Short-term Relief For Qualified Opportunity Fund Requirements

As a result of the continuing COVID-19 impact on businesses and individuals the IRS released a second Notice (IRS Notice 2021-10) on January 19, 2021 to provide Opportunity Zone (OZ) investors with additional time to roll capital gains into a Qualified Opportunity Fund (QOF), as well as additional time to make “substantial improvements” to acquired property and additional time to acquire Qualified Opportunity Zone Business Property (QOZBP).  This Notice follows the June 2020 Notice 2020-39 which extended various 2019 and 2020 OZ Program deadlines and testing dates – generally through December 31st. The extended relief under 2021-10 is generally through March 31, 2021.

Details of the relief given by Notice 2021-10 are outlined below:

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Jimmy Cox On Taxes In The Netherlands

According to a majority of the members of the European Parliament, the Netherlands is, just like Malta, Cyprus, Ireland and Luxembourg, a fiscal paradise and it is demanding (without any underlying jurisdiction, incidentally) that the European Commission place these five countries on its list of tax havens.  This list is, of course, is more akin to a pillory than an honor roll.

Does the Netherlands merit being designated as a tax haven?  Most inhabitants of the Netherlands would not experience this as being the case; after all, the VAT on shopping, for crying out loud, has increased by 50% this year alone, and the highest bracket in income taxation (over EUR 68,508) remains at 51.75%:  a solid deduction indeed.  It is true that taxation on company profits has decreased from 20 to 19%, but this latter figure is still considerably higher than in Ireland (12.5%) or Bulgaria (10%), for example.  Furthermore, companies making profits higher than EUR 200,000 continue to pay 25% over this threshold.

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International Tax Partner Job - Law Firm

TaxConnections has been retained by a leading multinational law firm to locate a Tax Partner to lead the Midwest region in serving  international clients. This market facing role is due to the continued expansion of the international and transfer pricing practice. The Tax Partner will team with a group of talented economists who are already in place to grow the Midwest tax practice. The law firm currently has about 80 tax lawyers worldwide and this successful practice is expected to double in size over the next five years.

Our client is happy to talk to Senior Tax Managers, Managing Directors or Principals who currently do not hold a Tax Partner title.

The Tax Partner will assist multinational clients to design, develop, implement, document and defend transfer pricing strategies. They will provide clients guidance in analyzing factual material, communicate the benefits of the transfer pricing methodologies both to government representatives and the courts and negotiate advance pricing agreements on a worldwide basis.

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TaxConnections Member Ron Wainwright

Tax Partner in the Raleigh office of Cherry Bekaert LLP with 25 years of experience in the area of taxation. As a Certified Public Accountant, Ron serves a diverse client base including multi-national, public and closely held companies.

Prior to working at Cherry Bekaert, Ron Wainwright was a tax partner with McGladrey for ten years along with a regional CPA firm and served in various National and Local leadership roles. Spent seven years in Washington, D.C. serving in a National Tax Role focusing on domestic and international tax issues, mergers and acquisitions and IRS Tax controversy matters.

A Steering Committee Tax Member with the National Association of Manufacturer’s and serves on the R&D Credit Coalition Committee. Was named to the “Who’s Who in American Business Leaders” in 2006, 2008 and 2010.

View a short video introducing tax advisor Ron Wainwright as a Presenter in the Internet Tax Summit.  See all Read More

TaxConnections would like to introduce you to Doug Eckert, Tax Partner with Brown, Smith, Wallace in St. Louis, Missouri.

Doug is a Partner and the International Tax practice leader in the Tax Services group of Brown Smith Wallace. With over 24 years of experience, he is skilled at advising on international expansion, developing global tax strategies, assessing global tax risk management and navigating the changing global tax environment.

His areas of expertise include global tax strategy development, cash repatriation strategies, transfer pricing, cross border disputes management, exporting initiatives, federal tax audit management, international tax compliance, and international expansion. Read More

TaxConnections would like to introduce Joseph Calianno.

Joe Calianno is a Tax Partner in BDO’s Washington DC National office. He practices in all areas of International Taxation and regularly advises on issues relating to cross-border restructuring and financing, subpart F, foreign tax credit planning, tax treaties and global tax rate reduction.

Joe has published numerous articles in national journals on international and corporate tax issues including articles in RIA’s Business Entities, CCH’s Global tax Briefing, CCH’s Journal of Passthrough Entities, CCH’s Journal of International Tax, International Tax Review, RIA’s Journal of International Taxation, RIA’s Journal of Corporate Taxation, RIA’s Journal of Taxation, Practising Law Institute, CCH’s Taxation of Global Read More

Introducing Tax Expert Doug Eckert, Tax Partner, Brown, Smith, Wallace, St. Louis, Missouri

 

Doug will be presenting at TaxConnections Internet Tax Summit and discussing the repatriation of funds without paying double taxation and various techniques you will want to know about.  His presentation begins Tuesday, September 22nd at 10:00AM (PST).

Gather your tax department for this informative session with Doug Eckert.

(See Video Introduction Below) Read More