Although investors can change banks and banking relationships with little difficulty, moving gold bars from vault to vault involves complicated logistics, costs, and risk. Moving gold bars between countries can also present legal hurdles, and, in some instances, the receiving financial institution may not even accept the bars because of their particular size or form. [...]
1031 exchanges have been a topic of Congressional discussion for decades. In California, for example, a Bill was introduced in 2010 to repeal the application of Internal Revenue Code Section 1031 to California taxes. But despite the occasional plea to eliminate or constrain the program, the outcome of those discussions has been that the benefits [...]
A 1031 Forward Exchange enables you to reduce or eliminate taxes on the sale of business or investment property. A 1031 exchange program is a great way for an exchanger to integrate 1031 exchanges into its ongoing buying and selling processes. Maximize your tax savings by using 1031 exchanges. Many taxpayers who utilize 1031 programs [...]
As you know, Internal Revenue Code Section 1031(f) disqualifies certain types of related party like-kind exchanges from receiving the beneficial tax consequences provided for Section 1031 exchanges. Recently, the North Dakota District Court looked at an LKE program for a Caterpillar dealer’s affiliate in North Dakota. In this case, North Central Rental & Leasing, LLC [...]
I hope that our readers on the Eastern Seaboard are doing alright in the aftermath of Hurricane Sandy. It was very difficult watching the destruction caused by Sandy, particularly because I had lived in New York City and Washington, DC for over 20 years before moving to California to join NES Financial. So I wanted [...]
Increasingly, states are enacting laws governing the business practices of qualified intermediaries (QIs) as a means to promote consumer protection. The State of Washington recently amended its QI law that was originally enacted in 2009. The state made some important changes to those laws, effective June 7, 2012, which are clearly designed to increase transparency [...]
As many of you already know, Section 897 of the Internal Revenue Code imposes taxation on the disposition of U.S. real property interests held by foreign individuals or foreign corporations by treating those persons as engaged in a trade or business within the U.S. and the gain from the disposition as effectively connected with a [...]
REITs are big users of 1031 exchanges and also frequent recipients of IRS private letter rulings on 1031 exchanges. A recent private letter ruling raises issues concerning whether a sequence of like-kind exchanges within a group of related entities, two of which are REITs, effectively gives the group of related exchangers extensions of the Section 1031 [...]
A recent ruling may signal changes for depreciation and 1031 exchanges of leased equipment. Are you prepared? The IRS is again challenging the status of leased equipment as “dual use” property where it is also available for sale or lease at the same time. Property that is considered to be held for sale is inventory [...]