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The Department of Treasury Releases Direct Pay Guidance on Clean Energy Tax Credits

Final Rules Address Eligibility and Process; Proposed Rules Provide Workaround Allowing Tax Exempts to Partner With Others on Projects - The Department of Treasury (Treasury) and the Internal Revenue Service (IRS) recently...more

COVID-19: State Tax Implications of Remote Working Arrangements

Prior to the coronavirus (COVID-19) pandemic, many state taxing authorities asserted that a business could become subject to their states’ tax obligations by having a single employee working from within the states, even if...more

The End of Capital Gains As We Know It? Wyden Releases Proposal Profoundly Changing How Capital Gains Are Taxed

The plan would tax all capital gains as ordinary income; end deferral of capital gains tax for the wealthy - Senate Finance Committee Ranking Member Ron Wyden (D-OR) recently released a proposal, “Treat Wealth Like Wages,”...more

Opportunity Zones: Second Round of Proposed Regulations Are Good News For Renewables, But Refinements Are Needed

The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more

IRS Shines a Spotlight on Syndicated Conservation Easements

The IRS has ramped up its enforcement efforts on syndicated conservation easements. On September 10, 2018, the IRS announced five new Large Business and International Division (“LB&I”) compliance campaigns, including a...more

Section 199A (to Z): Simplifying the Tax Code for Small Businesses is Complicated

The Internal Revenue Service (“IRS”) has released proposed regulations explaining how taxpayers should calculate the Section 199A deduction for qualified business income. ...more

What Do You Think About…Deemed Repatriation?

The tax reform bill signed into law by President Trump on December 22, 2017, taxes U.S. shareholders on their share of the previously untaxed deferred income of foreign corporations. Known as “deemed repatriation,” this tax...more

Impact of Tax reform on Commercial Real Estate

MOST SWEEPING TAX REFORM SINCE 1986 - Tax Cuts and Jobs Act signed December 22, 2017 - Generally effective for taxable years beginning after December 31, 2017 - Comprehensive tax reform affecting virtually all...more

Tax Reform and Investment Management: Effect on Registered Investment Companies

The Tax Cuts and Jobs Act (“Act”) significantly changed U.S. tax federal law. Although the Act does not amend any of the provisions directly affecting the qualification or other taxation of a “regulated investment company”...more

Tax-Free Cryptocurrency Transactions Could Come with Reporting Obligations

As cryptocurrencies such as Bitcoin and Ethereum become more prevalent in investment circles and acceptable for commercial transactions, the United States Internal Revenue Service (“IRS”) has said little other than to label...more

Getting Ready for the Main Course: Senate Finance Committee Leaders Outline "Blank Slate" Approach to Tax Reform

The momentum toward comprehensive tax reform accelerated significantly on June 27th, 2013, when the bipartisan leaders of the Senate Finance Committee, Chairman Max Baucus (D-MT) and Ranking Member Orrin Hatch (R-UT), sent...more

Fiscal Cliff II: What’s Next For Tax Reform?

On January 1, 2013, the Senate and House of Representatives passed the American Taxpayer Relief Act of 2012 (“ATRA”), signed into law by President Obama on January 2. ATRA averts the “fiscal cliff” by making permanent the...more

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