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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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