Income Taxes Capital Gains

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
News & Analysis as of

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

PEA PME-ETI: An Enhanced Version of the French PEA of Interest for EU Asset Managers

A new French tax law, effective since the beginning of this year, has generated much excitement by creating an enhanced favorable tax regime – the PEA PME-ETI – for individual investors. The new regime is similar to the Plan...more

Camp Goes All-In with Comprehensive Tax Plan: Highlights, Tax Reform Status and Impact on Taxpayers

On February 26, Representative Dave Camp (R-Mich.), chairman of the House Ways and Means Committee, released his much-awaited comprehensive tax reform plan (the “Camp Proposal”). That proposal seeks to cut marginal tax rates...more

Proposed Carried Interest Legislation Takes A Different Approach

On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more

The Boricua Option – The Taxation of Incentive Stock Options (ISOs) as a Puerto Rican Resident - Another Good Reason to Move to La...

Overview - Many professional living and working in Silicon Valley over the last twenty years have become very wealthy as a result of their participation in company stock options plans – qualified and non-qualified....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

Domestic double taxation relief applicable to capital gains derived by EU resident entities on disposal of shares in Spanish...

Following the non-discrimination principle, in response to an appeal dated 25 Octobe the Spanish Supreme Court has applied a tax credit to avoid double taxation, provided in the Corporate Income Tax Law for Spanish resident...more

CRESCENT HOLDINGS: An Issue of First Impression for Partners with Capital Interests

On December 2, 2013, the United States Tax Court issued an opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15. This opinion affects individuals who receive a non-vested capital interest in a partnership. In...more

Sale of dividend claims to third parties by non-resident taxpayers

Federal Ministry of Finance: If the capital gain is not taxable in Germany, the correspondent dividends are taxed. With its circular letter dated 26 July 2013, the Federal Ministry of Finance comments on the tax...more

Insight on Estate Planning - August/September 2013: Estate Planning Pitfall - You haven’t reviewed your trusts this year

If an estate plan includes one or more trusts, it’s a good idea to review them in light of recent tax law changes. Higher income taxes — on individuals as well as trusts — may make it advisable to rethink the way the trusts...more

No 15% Qualified Dividend Rate For CFC Inclusion

Back in 2011, we reviewed a Tax Court case that determined that income inclusion under the controlled foreign corporation (CFC) rules, while taxed like a dividend at ordinary income rates, could not qualify for the lower 15%...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

Native Title Taxation Measures Pass In Final Sitting Week (Australia)

SUMMARY - In its final sitting week, the Commonwealth Parliament passed three pieces of legislation which include important measures aimed at clarifying the taxation treatment of payments and benefits provided under...more

Spike In Real Estate Creates Tax Planning Opportunities For South Florida Property Owners

Although it may come as a surprise to many, it is no secret that South Florida property values are on the rise. ...more

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more

Taxation Of Computer Software Sales: Ordinary Income, Capital Gain, Or Both?

The taxation of computer software is complex, confusing, and in some circumstances, uncertain; although self-created computer software is routinely sold today, especially with the significant increase in the number of...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

Personal Planning Can Help Private Equity Pros Save on Taxes

When private equity or venture capital fund principals and managing partners look to roll out a new fund, in addition to reconciling general fund formation issues, they should consider the personal-planning opportunities...more

Under The Dome: Inside The Maine State House 4-5-13

This week, Governor LePage vetoed two bills: LD 49, An Act to Amend the Laws Governing Payment of Fees to Registers of Deeds, and LD 272, An Act to Reduce Youth Cancer Risk. These were the first vetoes of the 126th...more

Readjustment of Taxation of Free Floating Dividends and of Fiscal Unity – Current Legislative Procedures

Reform of taxation of free floating dividends for corporate income tax purposes The German Parliament (Bundestag) and the German Federal Council (Bundesrat) reached an agreement regarding the taxation of free floating...more

A Compilation of Enforcement and Non-Enforcement Actions - March 29, 2013

Non-Enforcement Matters: - Recent Newsworthy Remarks by the SEC - SEC Issues “Alert” on the Custody Rule - Securities Exchange Act Issues for Exchange-Traded Funds - Mutual Funds’ After-Tax Returns...more

Portability

Congress recently made permanent the “portability” of a predeceasing spouse’s unused estate tax exemption (currently, $5.25 million per spouse)....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

Moving from the Academic to the Legislative: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives...

BACKGROUND - For many years, academics have proposed that the U.S. replace the current hodge-podge U.S. federal income tax rules applicable to financial derivatives with a “mark-to-market” regime. In the first...more

Excluding 100% of Gain From the Sale of Qualified Small Business Stock Acquired in 2013

If you own a small business, it may be easier to raise money in 2013. This is because, among the favorable tax breaks included under the American Taxpayer Relief Act (the “2012 Act”), there is a temporary extension of the...more

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