NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
THE WONDER YEARS WEBINAR
Roetzel HealthLaw HotSpot: Optimizing Your Practice for Sale
Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Qualified Opportunity Zone Fund Investments
Episode 26: Talking Tax Reform and Executive Comp
Executive Compensation Packages – Interview with David Lagasse, Member, Mintz Levin
What Individuals and Businesses Need to Know About the American Taxpayer Relief Act
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
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
Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more
What are the tax accounting rules for hedges? Whether or not a qualified tax hedge is properly identified, it must be tax accounted for under a method that clearly reflects income. The timing of gains and losses on hedges...more
When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more
It is a common practice for businesses to manage their business price risks by entering into derivative contracts. Because their business activities generate ordinary income and loss, they want to obtain ordinary tax...more
BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more