by Greg Bryant | Jul 18, 2013 | Commercial Real Estate
The Court of Appeals for the Eleventh Circuit, affirming the Tax Court, has concluded that for depreciation purposes, a taxpayer couldn’t unilaterally change its original purchase price allocations in two asset purchase agreements entered into in connection with...
by Greg Bryant | Mar 20, 2013 | Commercial Real Estate
Parking Structures Recently there has been much discussion regarding the IRS General Counsel Memorandum # 20125201F. The memorandum pertains to the recommended assessment of a §6662 penalty on a taxpayer who took the position that an open air parking structure was a...
by Greg Bryant | Jan 23, 2013 | Commercial Real Estate, Tax
Although billions of dollars in research tax credits are generated each year, the credit still retains elements of complexity and misunderstanding. Companies often view the efforts of developing new products, improving legacy products, or enhancing outdated and costly...
by Greg Bryant | Nov 30, 2012 | Commercial Real Estate, Tax Planning
On Tuesday, November 20, 2012, the IRS issued Notice 2012-73 relating to the temporary regulations for the deduction and capitalization of expenses relating to the acquisition, renovation, or improvement of real estate. Notice 2012-73 informs us that the IRS will be...
by Greg Bryant | Sep 19, 2012 | Commercial Real Estate, Tax Planning
As we get ready to wrap-up the third quarter of 2012, it is a great time to explore the potential benefits of the various engineering-based tax solutions available today. Tax tools such as cost segregation, EPAct/Section 179D, and now the temporary regulations for...
