News & Analysis as of

Internal Revenue Service Asset Management

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DarrowEverett LLP

IRS Targeting Partnership Basis-Shifting Transaction Schemes

DarrowEverett LLP on

The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more

Proskauer - Employee Benefits & Executive...

A Pop Culture Guide to the Final Amendments to the QPAM Exemption Taking Effect on June 17, 2024

The DOL recently finalized amendments to the QPAM exemption that will considerably alter the exemption’s conditions effective as of June 17, 2024 (for a detailed summary of the changes, please see our post here). There are a...more

Gray Reed

Federal Income Taxation of Intellectual Property Development and Cost Recovery

Gray Reed on

Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more

Mayer Brown

United States: The Long Read - Lifetime Income Products in CITs on the Rise

Mayer Brown on

As recently noted by the US Department of Labor (“DOL”), since the passage of the Employee Retirement Income Security Act of 1974 (“ERISA”), “the retirement plan landscape has changed significantly, with a shift from defined...more

Blank Rome LLP

Avoiding Zero Basis for Inherited Assets

Blank Rome LLP on

Practitioners involved with the administration of trusts and estates of a decedent may be confronted with the issue of dealing with one or more assets of a decedent discovered after the administration is believed to have been...more

Proskauer - Tax Talks

Tax Court holds that an offshore fund is engaged in a U.S. trade or business

Proskauer - Tax Talks on

On November 15, 2023, the U.S. Tax Court held in YA Global Investments v. Commissioner that a non-U.S. private equity fund (YA Global) with a U.S. asset manager that bought equity and convertible debt of U.S. portfolio...more

Foodman CPAs & Advisors

Understanding Trusts So You Are Not Mislead By The Word “Trust”

Trusts are vehicles that can assist in the preservation of wealth and property for future generations, protect assets, or carry out a charitable purpose. A trust is an entity created and governed under the state law in which...more

Greenberg Glusker LLP

Top Tax and Legal Considerations for Wealthy Families Going Global

Greenberg Glusker LLP on

In recent years, we have seen high net-worth and ultra-high-net-worth families become, increasingly, “global citizens.” As families and their assets touch multiple jurisdictions, a myriad of issues become especially important...more

Goulston & Storrs PC

Massachusetts Doubles Estate Tax Threshold as Part of $1 Billion Tax Reform Act

Goulston & Storrs PC on

On October 4, 2023, Massachusetts enacted a new law called “An Act to improve the Commonwealth’s competitiveness, affordability, and equity” (the “Act”). The Act makes several tax law changes relevant to Massachusetts...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Foley & Lardner LLP

Another Fund Manager Sues IRS Over Application of “Limited Partner” Exception to Self-Employment Taxes

Foley & Lardner LLP on

On August 11, 2023, Stamford, Connecticut-based hedge fund manager Point72 Asset Management (“Point72”) filed a petition with the Tax Court contesting the IRS’s position that its owner, billionaire and New York Mets team...more

Cadwalader, Wickersham & Taft LLP

Limited Partner Exception Challenged by Hedge Fund Legend

An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more

ASKramer Law

Taxation of Derivatives Held by Investors: What to Know

ASKramer Law on

The taxation of derivatives and financial products has developed in an uncoordinated and piecemeal fashion. Tax rules have largely been enacted in response to what the government has perceived as abusive transactions —...more

Freeman Law

Why You Should Hire a Tax Professional to Review Your Trust

Freeman Law on

Trusts come in many variations, rendering them often difficult for non-attorneys to follow and comprehend.  Indeed, this variation can often be seen in the nomenclature used for trust arrangements, which includes terms such...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Estate Planning and Cryptocurrency

Digital assets, such as cryptocurrency, are becoming a larger component of investors’ portfolios. More and more people are owning some form of cryptocurrency....more

Shumaker, Loop & Kendrick, LLP

The Estate Planner, November/December 2022

Rising rates spark interest in charitable remainder trusts - If you wish to leave a charitable legacy while generating income during your lifetime, a charitable remainder trust (CRT) may be a viable solution. In addition...more

Seward & Kissel LLP

DOL Proposes an Amendment to the QPAM Exemption

Seward & Kissel LLP on

On July 27, 2022 the U.S. Department of Labor (DOL) proposed significant modifications to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption). The DOL will accept written comments and requests for public...more

McDermott Will & Emery

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

Kohrman Jackson & Krantz LLP

Passing Down Cryptocurrency Assets: Gifting And Estate Planning Considerations

WHAT IS CRYPTOCURRENCY? Cryptocurrency is a digital asset that is created and traded online. Miners (computer operators) establish new units of digital currency and record them on a blockchain, a string of verified public...more

Freeman Law

What is a Trust?

Freeman Law on

Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more

Robins Kaplan LLP

The Robins Kaplan Spotlight - VOL. 5, NO. 3 Fall 2020

Robins Kaplan LLP on

The Spotlight is the result of ongoing collaboration between our national trial practice and estate planning groups, with the goal of providing a forum to discuss the latest news and other issues impacting the trusts and...more

Steptoe & Johnson PLLC

Selling Assets to Reduce Your Estate Tax Exposure - Act Before September 30

Steptoe & Johnson PLLC on

If you have an estate that may be subject to estate tax next year, particularly if the November election results in a greatly reduced federal estate tax exemption in 2021, now is the time to remove assets from your taxable...more

Foodman CPAs & Advisors

This is the Time to Update Important Documents

By unexpectedly raising apprehensions regarding mortality and quality of life issues that many Individuals were not addressing prior to the pandemic, the Covid-19 pandemic is provoking  individuals to think about their...more

Vinson & Elkins LLP

[Event] REITs: IRS Ruling Opens Door For Midstream Assets - Feb. 12th, 12:00 pm CT (and available via webcast)

Vinson & Elkins LLP on

In the early 1990s, several MLPs converted into REITs to take advantage of better capital formation opportunities, but the REIT structure was not suitable for many midstream assets. Recent IRS guidance suggests this historic...more

Cohen Seglias Pallas Greenhall & Furman PC

IRA News: Beware, the IRS May be Your New Biggest Beneficiary

In May, the U.S. House of Representatives passed the “Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019.” If it becomes law, the SECURE Act will bring changes for individuals with retirement accounts....more

34 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide