News & Analysis as of

Net Investment Income Internal Revenue Code (IRC)

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

Rivkin Radler LLP on

Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Davies Ward Phillips & Vineberg LLP

Highlights of Canada’s Latest Legislative Tax Proposals

The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Wyrick Robbins Yates & Ponton LLP

Are My Taxes Going Up? Seven Proposals to Watch from the House Ways and Means Committee’s Draft Tax Legislation

Congress has other plans for tax practitioners this fall, starting with the House Ways and Means Committee’s initial draft of major tax legislation.  The draft legislation proposes far-reaching changes to existing tax laws,...more

Gray Reed

Taxation of Digital Collectibles: Sports, CryptoPunks and CryptoKitties, Oh My!

Gray Reed on

What do professional athletes, punk artwork and digital kittens have in common?  They are all part of the expansion of valuable collectible assets using cryptocurrency and blockchain technology.  You can collect digital items...more

McGuireWoods LLP

New Regulations Impact Excise Tax on Certain Private College and University Investment Income

McGuireWoods LLP on

Internal Revenue Code section 4968, enacted as part of the 2017 Tax Cuts and Jobs Act, imposes a 1.4 percent excise tax on the net investment income of certain private colleges and universities. The U.S. Treasury Department...more

Groom Law Group, Chartered

Significant Developments Affecting VEBAs – Final IRS Rules Clarify Unrelated Business Taxable Income (“UBTI”) Issues But Renew...

In December, the IRS/Treasury (“IRS”) published final rules addressing how employers that fund health and welfare benefits through a VEBA (i.e., a voluntary employees’ beneficiary association described in Section 501(c)(9) of...more

Proskauer - Not for Profit/Exempt...

Simplification of the Net Investment Income Tax for Private Foundations

On December 20, 2019, President Trump signed into law changes to the private foundation excise tax on net investment income under Section 4940 of the Internal Revenue Code. For purposes of Section 4940, net investment...more

BCLP

Section 4940 Excise Tax Simplification

BCLP on

Section 4940 of the Code imposes an excise tax on the “net investment income” of private foundations. Historically, the excise tax was 2%, with an opportunity for reduction to 1% for a year in which the foundation’s...more

Proskauer - Tax Talks

Tax Planning Under the Tax Cuts and Jobs Act: Flow-Throughs Are the Answer to Everything

Proskauer - Tax Talks on

The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more

Dickinson Wright

Key Tax Changes in the American Health Care Act

Dickinson Wright on

The American Health Care Act ("AHCA"), passed by the House of Representatives on May 4, 2017, repeals many of the taxes added by the Affordable Care Act ("ACA") and makes changes to other tax rules. Some of the notable...more

Blank Rome LLP

Application of Net Investment Income Tax to Section 453A Interest

Blank Rome LLP on

Although the Internal Revenue Service (IRS) has not directly addressed this matter, interest accruing from installment agreements sales under Internal Revenue Code (IRC) section 453A is likely not included in net investment...more

McDermott Will & Emery

NYS Tax Department Relaxes Investment Income Identification Rules

McDermott Will & Emery on

The New York State Department of Taxation and Finance has announced that it would extend the time for certain taxpayers to identify stocks as being held for investment so that income from those stocks would be tax-exempt [TSB...more

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