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IRS Issues Proposed Regulations Relating to Digital Asset Transactions

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) recently released proposed regulations (REG-122793-19) pertaining to information reporting and backup withholding, as well as basis and...more

Summary of Certain Business Tax Provisions in the Consolidated Appropriations Act, 2021

After much political gridlock, Congress passed an omnibus government-spending bill (Appropriations Act), which includes another COVID-19 relief package. The Appropriations Act contains many tax-related provisions. Some of the...more

IRS Publishes Proposed Regulations Applicable to Three-Year Carried Interest Holding Period Requirement

08.05.2020 | Updates On Friday, July 31, 2020, the Internal Revenue Service (IRS) issued proposed regulations under Section 1061 of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and Jobs Act, Section 1061...more

Summary of Tax Provision of the Families First Coronavirus Response Act and Certain Tax Filing Changes

In response to the ongoing coronavirus (COVID-19) pandemic, the U.S. Congress, the Executive Branch, and the Internal Revenue Service (the IRS) have taken several actions intended to provide immediate relief to taxpayers,...more

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

New Three-Year Hold Requirement for Carried Interests

The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more

Impact of Tax Reform on Some Private Company Equity Awards: Limited Income Tax Deferral Opportunities for Employees

The recent tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act includes a new income tax deferral regime for certain employee stock options...more

Tax Cuts and Jobs Act of 2017: Year-End Planning for Businesses

The tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act contains a number of provisions that create significant year-end planning...more

Capital Gains Tax Exclusion for Certain New Investments in Small Businesses Made Permanent

President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) on December 18, 2015. Among other provisions, the PATH Act provides that the 100 percent exclusion from gross income of...more

Don’t Burst My Bubble! IRS Provides Clarity for F Reorganizations

Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more

Investment Window For Capital Gains Tax Exclusion For Certain New Investments In Small Businesses Extended To December 31, 2013

On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the Act). Among other provisions, the Act provides that the 100% exclusion from gross income of certain capital gains from sales...more

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