Jonathan Goldman

Jonathan Goldman

Sutherland Asbill & Brennan LLP

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Virtual Reality: IRS Provides Guidance on the Treatment of Bitcoin and Other Virtual Currency Transactions

On March 25, 2014, the Internal Revenue Service (IRS) issued Notice 2014-21 (the Notice), which provides guidance regarding the tax treatment of Bitcoins and other virtual currency through a series of “frequently asked...more

4/1/2014 - Bitcoins FBAR Income Taxes Investment Funds IRS Virtual Currency

Legal Alert: Energy Tax Reform: Current Updates And What It Means For Companies In The Energy Sector

Energy tax reform has been the subject of three recent, and very significant, administrative and legislative proposals: - The President’s 2015 budget, released on March 4, 2014; - The comprehensive tax reform plan...more

3/17/2014 - Energy Energy Tax Incentives Tax Reform

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

3/6/2014 - Capital Gains Corporate Tax Rates Corporate Taxes Employee Benefits Energy Executive Compensation Foreign Nationals Income Taxes Insurance Companies Net Investment Income Partnerships Real Estate Market REIT RICs S-Corporation Tax Credits Tax Deductions Tax Reform Tax Returns

DQ’d: New Inversion Regulations Expand the Reach of the Public Offering Rule and Offer a Few Other Surprises

On January 17, Treasury and the IRS published new temporary and proposed regulations under Section 7874 of the Internal Revenue Code that expand the reach of the so-called “public offering rule” of Section 7874(c)(2)(B) to...more

1/23/2014 - De Minimus Quantity Exemption Internal Revenue Code Inversion IRS Public Offerings Stocks U.S. Treasury

Legal Alert: Not Exactly a Day in the Sun: U.S. Court of Appeals Holds Private Equity Fund Is Engaged in a Trade or Business

In Sun Capital Partners III LP v. New England Teamsters & Trucking Industry Pension Fund, No. 12-2312, 2013 WL 3814984 (1st Cir. July 24, 2013), the U.S. Court of Appeals for the First Circuit effectively found that the...more

8/1/2013 - ERISA Fund Managers Investment Funds Pensions Pooled Investment Vehicles Private Equity Private Equity Funds Sun Capital Partners

Legal Alert: Tax Court Finds Indirect Prohibited Transaction in IRA

In Peek v. Commissioner (May 9, 2013), the U.S. Tax Court ruled that two taxpayers had engaged in an indirect “prohibited transaction” with their individual retirement accounts (IRAs) when they provided personal guarantees...more

5/22/2013 - ERISA IRA Prohibited Transactions Promissory Notes

Legal Alert: IRS Clarifies "Binding Written Contract" Definition in Renewable Energy Tax Credit Begun Construction Guidance

On April 25, 2013, the Internal Revenue Service updated guidance issued on April 15, 2013, that explained how to satisfy the new “begun construction” requirement for the renewable energy section 45 production tax credit (PTC)...more

4/29/2013 - Begun Construction Test Damages Investment Tax Credits IRS Production Tax Credit Renewable Energy Tax Credits Written Agreements

Have You "Begun Construction"? IRS Issues Guidance for Renewable Energy Tax Credits

On April 15, 2013, the Internal Revenue Service ( IRS) issued much - anticipated guidance that will help developers of wind, solar, biomass and certain other renewable energy facilities qualify for federal renewable energy...more

4/17/2013 - Begun Construction Test Fiscal Cliff Investment Tax Credits IRS Production Tax Credit Renewable Energy

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

On January 24, House Ways and Means Committee Chairman Camp (R-MI) released a discussion draft of proposals to reform the taxation of certain financial instruments and products (the Camp Draft). In brief, the Camp...more

1/30/2013 - Camp Draft Capital Gains Derivatives Hedge Funds Income Taxes

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