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Capital Gains Taxable Income

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

ASKramer Law

Business Taxation of Hedging Transactions Part IV: Tax Timing

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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

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

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Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

Rivkin Radler LLP

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

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The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

Rivkin Radler LLP

Will New York Increase Taxes On Investment Income?

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Last Thursday, New York State Senator Gustavo Rivera, who represents the 33rd District (basically, the northwestern quadrant of The Bronx), proposed legislation that seeks to collect more taxes from the State’s high-income...more

Cadwalader, Wickersham & Taft LLP

Staking Rewards: Is IRS Digging In or Changing Its Mind?

Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more

Rivkin Radler LLP

Attention Congress: Focus On the Estate Tax Regime; Leave the Income Tax Alone

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“Déjà vu All Over Again”- The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...more

Rivkin Radler LLP

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

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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

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

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Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...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

Rivkin Radler LLP

Tax Highlights: The American Families Plan

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In advance of the President’s address to Congress this evening, the White House this morning released a summary of Mr. Biden’s proposed changes to the Internal Revenue Code. These changes, together with his previously...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Gerald Nowotny - Law Office of Gerald R....

Knock Yourself Out Resuscitating Taxpayers With Buyer’s Remorse!

One of the feelings that all of us living on the Planet including those who have walked before us, experience is the remorse for actions taken or sometimes not taken, i.e., buyer's remorse. Individual taxpayers report their...more

Mayer Brown Free Writings + Perspectives

On point. – Real Estate Investment Trusts (REITs)

Real estate investment trusts (“REITs”) are professionally managed companies that invest in real estate, mortgages and real estaterelated assets on behalf of their investors. Established in 1960, REITs were designed to...more

Farrell Fritz, P.C.

The “Art” Of Operating Foundations: A Public-Private Venture

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In the Beginning- From the dawn of recorded history, those who have the means have purchased or otherwise financed the work of those whom we call artists – talented individuals capable of producing what we call works of...more

Farrell Fritz, P.C.

NYC Real Estate: Post-Virus Tax Planning Can Help

Farrell Fritz, P.C. on

NYC Real Estate on the Ropes- In March of this year, the Department of Homeland Security classified real estate as an “essential business.” I imagine that the person in Washington who suggested that real estate be added to...more

Vinson & Elkins LLP

REIT-Specific Tax Considerations In The COVID-19 Era

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As a result of COVID-19, the markets have been in turmoil and businesses — and thus, tenants and borrowers — have been struggling. Real estate investment trusts (“REITs”) are facing, and will continue to face, additional...more

Goodwin

Internal Revenue Service Clarifies Tax Treatment of Crypto in Certain Instances

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On October 9th, the IRS released a revenue procedure ruling and related FAQ, clarifying tax treatment related to cryptocurrency in certain instances. The ruling focused on tax treatment of hard forks and airdrops, and...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Guidance Regarding Virtual Currency Transactions

On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more

Latham & Watkins LLP

The Future Ain’t What It Used to Be: New Tax Guidance Issued for Cryptocurrencies

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The IRS has published a Revenue Ruling and FAQs clarifying some long-standing virtual currency questions. On October 9, 2019, the US Internal Revenue Service (IRS) issued its first guidance on the tax treatment of...more

Lowndes

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

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One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Dechert LLP

Global Private Equity Newsletter - Summer 2016 Edition: LBO & Management Packages In France: Are Recent Developments In The...

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The management packages offered to managers in LBOs can sometimes be differentiating factors for financial sponsors enabling them to win a competitive process for the acquisition of a target company. However, although...more

Dechert LLP

German Investment Taxation – Reform Ahead

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The German Ministry of Finance (Bundesfinanzministerium) circulated a discussion draft bill on the reform of fund taxation (‘Draft Bill’) on 22 July 2015. The Draft Bill contains significant changes to the German tax...more

Troutman Pepper

Tax Proposals to Eliminate Interest Deductions Miss the Mark

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The proposal to eliminate the interest deduction may have a material adverse impact on U.S. middle-market companies. In March, Republican presidential candidate Senator Marco Rubio, together with Senator Michael Lee,...more

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