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Capital Gains Capital Assets

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

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Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source

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Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more

ASKramer Law

Valuing Noncash Charitable Donations, Including Digital Assets

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As we’re approaching year end, this is a good time to revisit the tax rules that apply to donating noncash property—including donations of digital assets....more

McDermott Will & Emery

Washington State Capital Gains Tax Upheld; Payments Due April 18

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The amount of taxes due this year for many Washington state taxpayers just increased following a 7-2 decision from the Washington Supreme Court in which it reversed a lower court’s ruling and held that the state’s new capital...more

McDermott Will & Emery

IRS Releases Notice on the Taxation of NFTs as Collectibles

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In its first published guidance addressing non-fungible tokens (NFTs), the Internal Revenue Service (IRS) released Notice 2023-27 on March 21, 2023, announcing its intent to issue guidance related to the taxation of certain...more

Foley & Lardner LLP

IRS Issues Notice on Treatment of NFTs as Collectibles

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On March 21, 2023, the Internal Revenue Service (the IRS) released Notice 2023-27 (the Notice) announcing that the Treasury Department and the IRS intend to issue guidance related to the treatment of certain Non-Fungible...more

ASKramer Law

Taxation of Stock Options Held by Investors: What to Know

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When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more

White and Williams LLP

FOURTH QUARTER ALERT: 100% Bonus Depreciation Deduction Expires December 31, 2022

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As we move into the final quarter of 2022, it is critical to take note of an expiring tax benefit in the Tax Cuts and Jobs Act (TCJA). Passed in 2017, it allows for 100% bonus depreciation on a wide variety of capital assets...more

Lasher Holzapfel Sperry & Ebberson PLLC

Washington’s New Capital Gains Tax is Overturned as Unconstitutional

In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Like-Kind Exchanges Under IRC Section 1031: A Primer

Individual and business clients engaging in real estate transactions often have an interest in like-kind exchanges under Internal Revenue Code Section 1031 (hereinafter “1031” or “Section 1031”). Clients are usually aware...more

McDermott Will & Emery

Weekly IRS Roundup October 11 – October 15, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 11, 2021 – October 15, 2021... October 12, 2021: The IRS released a notice, announcing...more

Rivkin Radler LLP

An Open Letter To The Incoming NY Governor, Kathy Hochul

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Welcome to the Governor’s office, Ms. Hochul. Unfortunately, congratulations are hardly in order; indeed, a wish for good luck seems much more appropriate. I suppose you realize that the last round of tax legislation,...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

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A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

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The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Sullivan & Worcester

Opportunity Zone Best Practices – Not All Extensions are Automatic

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The IRS recently issued additional Opportunity Zone-related guidance, Notice 2020-39, that grants extension relief with respect to five specific time-sensitive actions. Among other things, Notice 2020-39 (i) allows certain...more

Pillsbury Winthrop Shaw Pittman LLP

A Single Asset Bankruptcy from the 1990s Gains New Relevance during COVID-19

Three Flint Hill may provide valuable lessons on the use of bankruptcy to reduce real estate debt to match present property values. Chapter 11 strategies may exist for valuable real estate assets that are not producing...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

Polsinelli on

Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”).  These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more

Stinson LLP

Opportunity Zone Final Guidance

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The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary....more

Lowndes

Act Before Year-End To Maximize Opportunity Zone Tax Benefits

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As 2019 comes to a close, there is an important deadline approaching for opportunity zone investors. December 31, 2019 is the last day on which investors can make an investment in a qualified opportunity fund (“QOF”) and...more

Troutman Pepper

Highlights of New Opportunity Zone Regulations

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In April, the Department of the Treasury released the second round of regulations related to the opportunity zone program. Some highlights include... Originally published in Middle Market Growth, the official publication...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

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After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more

Flaster Greenberg PC

Guide to the Surprises Lurking in the QOZ Proposed Regulations

Flaster Greenberg PC on

While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

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BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

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