News & Analysis as of

Tax Implications: Selling Your Home

If you've lived at a property for at least two out of the five years before you sell your home, you can consider that property your primary residence or "main home", per the Internal Revenue Service. The IRS will then...more

Why You Should Keep Stockbroker Receipts

Gains from the sale of property are generally subject to federal (and, usually, state) income tax (sometimes referred to as “capital gains tax”). The amount of gain subject to tax is equal to the sale proceeds less the...more

High Net Worth Family Tax Report, Vol. 9, No. 1

In This Issue: - Congressman Camp Camp Releases His Long-Awaited Tax Reform Plan - Tax Court Addresses Valuation Issues Related to Tax on Built-In Corporate Gain - Shareholder of S Corporation Required to Include...more

Taxation Of Copyright Sales: Ordinary Income Or Capital Gain?

Tax day presents several interesting questions for copyright holders, not the least of which is how the Internal Revenue Service (IRS) will treat income from the sale or exclusive license of a copyright. If a copyright is a...more

IRS Releases Bitcoin Guidance; May Have A Chilling Effect On Virtual Currency

Last week, the IRS released IRS Notice 2014-21 (the “Notice”), its first guidance on the income tax treatment of virtual currency, including, bitcoin. A copy of the notice can be obtained at...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

New Section 336(e) Election Provides Additional Flexibility in Taxation of Stock Transactions

On May 15, 2013, the Department of the Treasury issued final regulations regarding a new election now permitted under Section 336(e) of the Internal Revenue Code that allows sellers to elect to treat transactions structured...more

NRA Gain On Sale Of Partnership Interest Treated As Creating Effectively Connected Income

Nonresidents are generally not subject to U.S. income taxes on their capital gains if present in the U.S. for less than 183 days in the tax year. Code Section 741 treats the gain from the sale or exchange of a partnership...more

Treasury Finalizes Regulations on Noncompensatory Partnership Options

The U.S. Treasury Department recently released regulations on the tax treatment of noncompensatory options issued by a partnership, as well as proposed regulations addressing the threshold question of when a partnership...more

Tax, Benefits and Nonprofit Organizations Client Alert: New Tax Regulations on Noncompensatory Partnership Options

Overview - The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations), effective February 5, 2013, concerning the tax consequences of...more

Congress Extends Exclusion for Investors in Qualified Small Businesses

Among the taxpayer-favorable aspects of the American Taxpayer Relief Act of 2012 (Act), the 100 percent exclusion from gross income of gain on the sale of Qualified Small Business Stock (QSBS), provided for in section 1202 of...more

New 3.8% Tax on “Net Investment Income” – IRS Issues Proposed Regulations

The Internal Revenue Service has issued Proposed Regulations under Section 1411 of the Internal Revenue Code providing guidance on the 3.8% additional tax that will be imposed beginning January 1, 2013 on the “net investment...more

Post-Election 2012 Tax Planning Alert: Practical Tax Planning Tips for You, Your Family and Your Business

This Alert is designed to offer easy to understand and easy to implement year-end tax strategies in times of incredible tax uncertainty. This Alert is also designed to stimulate thought and inspire action during one of the...more

New 3.8% Medicare Tax on Investment and Unearned Income Beginning in 2013

Starting January 1, 2013, a new 3.8% Medicare tax will apply to the investment and “unearned income” of individuals, trusts and estates. The tax is intended to apply to income exempt from the regular FICA or self-employment...more

2012 Year-End Income, Estate & Gift Tax Planning

With 2012 drawing to a close, many Americans may see the end of “Bush-era” income tax cuts as well as significant estate and gift tax reductions, the loss of which will dramatically affect their tax liability in 2013 and...more

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