News & Analysis as of

Capital Gains Investors

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

ASKramer Law

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

ASKramer Law on

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

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

Rivkin Radler LLP on

This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more

Mintz - Employment Viewpoints

Show Me The Money! Trends in Executive Compensation

As the calendar inches closer to 2024, a pivotal concern looms large in the minds of most employees: cash bonuses. However, for executives, especially those who work for private companies that may be involved in a...more

Dechert LLP

New Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including Access to Treaty Benefits for CIVs / Investment Funds

Dechert LLP on

Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more

WilmerHale

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

WilmerHale on

In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

Rivkin Radler LLP on

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

ASKramer Law

Taxation of Stock Options Held by Investors: What to Know

ASKramer Law on

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

Bowditch & Dewey

How Can I Have Capital Gains Tax When My Mutual Fund Lost Money?

Bowditch & Dewey on

Many mutual fund investors have seen their mutual fund investments drop 30% or more in 2022. The Fidelity Growth Company Fund (FDGRX) is down 33.78% for 2022. The Vanguard US Growth Fund Investor (VWUSX) is down 39.64%....more

Patterson Belknap Webb & Tyler LLP

Avoiding a Trap for the Unwary: Gains from Secondary Sales Treated as Compensation

Founders and other employees of private companies commonly employ sales of stock in the secondary market as a means of accessing cash prior to an offering or exit. Such sales are typically structured as a direct purchase of...more

McDermott Will & Emery

Gewerbesteuerpflicht auf Mieterträge und Veräußerungsgewinne bei Grundstücksverwaltung in Deutschland?

McDermott Will & Emery on

NEUES BFH-URTEIL ZU INLÄNDISCHEN BETRIEBSSTÄTTEN. Für Immobilieninvestoren, die mit ausländischen Gesellschaften in deutsche Immobilien investieren, ergeben sich regelmäßig Unsicherheiten aus der Frage, ob Dienstleister...more

Whitman Legal Solutions, LLC

Tax Treatment of Carried Interests Not Likely to Change This Year

Just over a week ago, in Changes to Tax on Carried Interest Would Lead to Conflicts of Interest, I wrote about a proposal in Congress to modify the tax laws relating to carried interests. However, now like Ko-Ko, carried...more

BCLP

Tax changes to Luxembourg structures investing in UK real estate

BCLP on

The UK and Luxembourg have renegotiated their double tax treaty. The new treaty has been published, but is not yet in force. Significant changes have been made to the capital gains tax article amongst other provisions....more

Bradley Arant Boult Cummings LLP

VAS Holdings and the Battle Over Taxing Non-Unitary Capital Gains

Is the unitary business principle the sole test for determining whether a state can tax an apportioned share of a non-domiciliary’s capital gains under the U.S. Supreme Court’s Due Process Clause and Commerce Clause...more

Smith Gambrell Russell

Deadlines for Investing 2021 Gains in Opportunity Zones

Smith Gambrell Russell on

M&A activity set a new record in 2021, reaching $5.8 billion globally.[1] After such a heated year of sales, mergers, and financings, those investors who saw taxable gains must now account for the inevitable tax bills. One...more

McDermott Will & Emery

The Working Capital Safe Harbor

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

What Is a QOF?

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

How to Invest in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Bowditch & Dewey

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

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In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Rivkin Radler LLP

Disposing Of Assets Under The Ways and Means Committee’s Proposals

Rivkin Radler LLP on

First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more

Gould + Ratner LLP

New Tax Bill Puts a Stop to Incentives for Startup Investing

Gould + Ratner LLP on

Proposal’s Effect Would Limit Access to Capital for Small Businesses - An overlooked provision of the new, sweeping tax bill currently under consideration by Congress as part of President Joe Biden’s $3.5 trillion...more

Smith Anderson

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

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With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

Husch Blackwell LLP

Biden's Green Book Includes Retroactive Capital Gains Tax Increase

Husch Blackwell LLP on

On Friday, May 28, 2021, the Biden Administration released its Green Book setting out the President’s revenue and policy proposals. Of particular interest to investors is the administration’s proposal to raise the tax on...more

Cole Schotz

Qualified Opportunity Zone Investing: A Life Saver For Tax Reform

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The Biden tax reform proposals target many tax benefits associated with real estate investing. If adopted, the ability to do tax free like kind exchanges may be eliminated and the maximum long term capital gains rates on...more

Gray Reed

The IRS is Hunting for Cryptocurrency Investors with John Doe Summonses

Gray Reed on

The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply.  One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more

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