News & Analysis as of

Reporting Requirements Capital Gains

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

Fox Rothschild LLP on

The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

ASKramer Law on

When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

Rivkin Radler LLP on

Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

International Lawyers Network

Establishing a Business Entity in India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Bilzin Sumberg

Inflation Adjustments for 2024: Key Information for International Private Client Practitioners

Bilzin Sumberg on

The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on

Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

International Lawyers Network

Establishing A Business Entity In India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Cadwalader, Wickersham & Taft LLP

Is Staking a Taxable Service?

On February 3, the Proof of Stake Alliance (“POSA”), a cryptocurrency industry association, issued a press release regarding recent developments in a cryptocurrency tax case, in which the IRS approved the tax refund sought by...more

Obermayer Rebmann Maxwell & Hippel LLP

Call to Increase Transparency Of Opportunity Zone Program

From the date of its inception, the Opportunity Zone Program has been criticized for its lack of transparency and reporting requirements. The original version of the law included reporting requirements, but some of those...more

International Lawyers Network

Establishing A Business Entity In India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Dechert LLP

Cryptocurrency Stakeholders Should Prepare for Increased Tax Enforcement

Dechert LLP on

As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Hogan Lovells

Spain: Law 11/2021 implementing ATAD and other measures against fraud

Hogan Lovells on

The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Foodman CPAs & Advisors

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more

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

First Look: Select Tax Provisions in the Proposed American Families Plan

On April 28, President Biden announced the American Families Plan. The American Families Plan is touted as an investment in America’s children and families – helping families cover basic expenses that so many struggle with...more

Gray Reed

The IRS is Hunting for Cryptocurrency Investors with John Doe Summonses

Gray Reed on

The IRS has several tools in its arsenal to encourage compliance and audit and enforce those it believes are failing to comply.  One of the most powerful tools is the John Doe summons. A regular IRS summons seeks information...more

Foodman CPAs & Advisors

Did You Engage In Virtual Currency Transactions In 2020?

Taxpayers who engaged virtual currency   transactions in 2020 must answer a Yes or No Question on page 1 of Form 1040 or Form 1040-SR. The question is: “At any time during 2020, did you receive, sell, send, exchange or...more

International Lawyers Network

Establishing A Business Entity In India (Updated)

1. Types of Business Entities - 1.1 Description of the types of entities available in India through which to conduct business: A foreign entity may establish a business presence in India by: • opening a liaison...more

Gray Reed

Taxpayer Guidelines for Cryptocurrency in 2021

Gray Reed on

Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

Ballard Spahr LLP on

On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Ballard Spahr LLP

IRS CI Highlights International Efforts to Tackle Cryptocurrency Abuse, Money Laundering and Tax Evasion

Ballard Spahr LLP on

ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals - The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more

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