News & Analysis as of

Capital Losses

“Abandonment Of A Partnership Interest,” Or “When A Taxpayer Rejects Its Tax Return Position”

by Farrell Fritz, P.C. on

“Disposing” of a Partnership Interest- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer his adjusted basis for the interest – i.e.,...more

Capital Gains Tax decision in SCA

by Hogan Lovells on

On 28 March 2017, a judgment was handed down by the Supreme Court of Appeal (SCA) regarding capital gains tax owed by a taxpayer on the proceeds of a sale agreement from 2007 that was cancelled more than three years later....more

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

New Saudi Companies Law – Accumulated Losses and Risk of Statutory Dissolution

by Latham & Watkins LLP on

For the past few decades, the obligations of companies with losses reaching 50% or more of their share capital has been a topic of high debate in the Kingdom of Saudi Arabia. That is due to the uncertainty surrounding the...more

Taxpayer Entitled to Capital Loss from Property Foreclosure for Year of Sale, Not When Proceeds Received

by Miles & Stockbridge P.C. on

Evans v. Commissioner, T.C. Memo. 2016-7, was recently decided. The taxpayer in this case was an individual who worked full-time at a real estate development firm. The taxpayer also purchased residential real estate...more

Tax Court Clarifies Meaning of Worthlessness for Real Property Loss Deductions

by Miles & Stockbridge P.C. on

In the recently published case of Tucker v. Commissioner, T.C. Memo 2015-185, the Tax Court held that a taxpayer was not entitled to a loss deduction for real property subject to a recourse mortgage unless and until a...more

UK 2015 Summer Finance Bill Update: Proposed Taxation Changes for Carried Interest and DIMF

by Proskauer Rose LLP on

Further to our client alert in July this year, the UK Government recently proposed further changes to the UK taxation of carried interest and disguised investment management fees (DIMF). The UK Government proposed...more

New Stock Identification Requirements for New York Corporate Tax Exemption

by Proskauer Rose LLP on

Effective for tax years beginning on or after January 1, 2015, pursuant to legislation enacted last year, income from "investment capital" is exempt from New York State franchise tax for corporate taxpayers otherwise subject...more

Inside the New York Budget Bill: Department Issues Guidance Regarding Investment Capital Identification Procedures

by McDermott Will & Emery on

On July 7, 2015, the New York Department of Taxation and Finance issued guidance (TSB-M-15(4)C, (5)I, Investment Capital Identification Requirements for Article 9-A Taxpayers) on the identification procedures for investment...more

No Theft Loss for Securities “Pump-and-Dump”

by Charles (Chuck) Rubin on

Pump-and-dump occurs when corporate officers or other shareholders fraudulently promote shares of a company and engage in fraudulent sales to increase the value of shares. This is injurious to other shareholders who suffer...more

Bitcoin and the Like: Further Tax Developments to Monitor

by BakerHostetler on

Virtual currency developments continue to emerge, including state tax guidance, a court decision on deductibility of losses, and the Uniform Fiduciary Access to Digital Assets Act (the “Act”). State Tax Guidance - The New...more

Should You Abandon An Underperforming Partnership?

Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

5th Circuit Allows Ordinary Loss for Stock Abandonment

by Goulston & Storrs PC on

Wednesday, the 5th circuit reversed the Tax Court and held in Pilgrim’s Pride that a taxpayer could receive an ordinary loss on the abandonment of a stock interest....more

Abandonment Losses Back on the Table!

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

Frequently Forgotten Divorce Asset: Loss Carry-Forwards

by Jaburg Wilk on

Loss carry-forward is a frequently forgotten asset in divorces. Whether the loss arises from the operation of a business (Net Operating Loss) or sale of stocks (capital loss), it is a valuable asset which may be used to...more

Required Summer Reading: Guidance Issued on the Tax Treatment of Guaranteed Minimum Benefit Hedges and Identified Mixed Straddles

The Treasury and the IRS offered two pieces of highly anticipated guidance on July 18 that are particularly relevant to the life insurance industry. ...more

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

by Morrison & Foerster LLP on

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

The bond breakthrough

by White & Case LLP on

In November 2012, Barclays raised a US$3bn corporate bond with a difference. The bank issued a contingent capital note (or coco) – a bond that automatically converts into equity as soon as a bank incurs losses that reduce its...more

Treasury Finalizes Regulations on Noncompensatory Partnership Options

by McDermott Will & Emery on

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

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