Let's Talk About the Anatomy of a Prenuptial Agreement
Advancing Agriculture: Security Interests and Article 9 Challenges (Part 2)
More than a decade after the associated property rule was invalidated by the U.S. Court of Appeals for the Federal Circuit in Dominion Resources, Inc. v. United States, 681 F.3d 1313 (Fed. Cir. 2012), the U.S. Department of...more
The application cycle for the first round of credits will soon open. Treasury’s additional guidance clarifies what types of facilities may qualify for credits, the submission process and the selection criteria for evaluating...more
In Notice 2014-21, the IRS announced its position that cryptocurrencies constitute property for tax purposes, rather than foreign currency, and observed that while cryptocurrency may operate like “real” currency in some...more
Digital assets, such as cryptocurrency, are becoming a larger component of investors’ portfolios. More and more people are owning some form of cryptocurrency....more
Cryptocurrencies are becoming a larger component of investors' portfolios, especially for millennials and Generation Z, who collectively make up 94 percent of cryptocurrency buyers. While it may seemingly be too early for...more
This Insights blog is Part 2 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more
The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more
In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more
The Internal Revenue Service (IRS) can file a lien and levy on any and all of a taxpayer's property (and rights to property) regardless of how the property is held or titled. 26 U.S.C. § 6321. Whether the item is a taxpayer's...more
In a US District Court complaint filed May 26, 2021, a married couple is seeking a refund of taxes they paid on cryptocurrency tokens the husband created, asserting that current law does not permit the treatment of created...more
“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
The Treasury Department and the IRS received 21 written comments in response to the like-kind exchange proposed regulations (see our earlier alert). The recently issued final IRS like-kind exchange regulations adopt some...more
In 2017, the Tax Cuts and Jobs Act modified the rules for like-kind exchanges to apply only to real property not held primarily for sale. Prior to the Tax Cuts and Jobs Act, exchanges of machinery, equipment, vehicles,...more
On June 11, the IRS released Proposed Treasury Regulations (the Proposed Regulations) under Section 1031 of the Internal Revenue Code, as amended (the Code), which provide a much-awaited definition of “real property” and...more
July 2020 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intrafamily Loans and Split-Interest Charitable Trusts - The July Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs...more
The Taxable Exchange- As a general rule, a taxpayer’s exchange of one property for another property is treated as a taxable event; the gain realized by the taxpayer – meaning the amount by which the fair market value of...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
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
Within the past year, the IRS has not changed its position on the way they are treating the taxation and reporting of digital token transactions. This alert serves as an update to last year’s rundown of cryptocurrency...more
The Southern District of New York is deciding whether a putative class action can proceed beyond the motion to dismiss phase in a lawsuit that may implicate how banks define crypto currency purchases, and how those purchases...more
The IRS recently reminded taxpayers that like-kind exchanges are now generally only available for exchanges of real property. This change was enacted as part of the Tax Cuts and Jobs Act passed in December of last year. ...more
There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more
With the individual tax filing deadline approaching it is a good time to visit the tax treatment of your bitcoin and other cryptocurrency transactions from 2017. With the increase in publicity and use of cryptocurrencies,...more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more
Recent federal legislation adds fresh compliance burdens to an old concept in federal tax law: the step-up in tax basis of appreciated property at death. New reporting requirements will apply to estates required to file a...more