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Securities Internal Revenue Code (IRC)

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

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This article is the third in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

K&L Gates LLP

DOL's Fiduciary Rule: The Latest Developments

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In July, two Federal District Courts in Texas issued orders staying the effective date of the Department of Labor’s (DOL) fiduciary rule (Fiduciary Rule)....more

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

McDermott Will & Emery

Weekly IRS Roundup May 13 – May 17, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 13, 2024 – May 17, 2024....more

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

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Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

McDermott Will & Emery

Key Digital Asset Tax Proposals in the Biden Administration's Green Book

On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more

McDermott Will & Emery

Can Virtual Currency Traders Elect into Special Rules that Allow Current Deductions for Trading Losses?

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Traders in virtual currency seeking to deduct trading losses and avoid application of the capital loss limitations would want to elect into the special tax rules found at I.R.C. § 475(f). However, such taxpayers should...more

McDermott Will & Emery

When Virtual Currency Positions Are Subject to the Wash Sales Rule

McDermott Will & Emery on

Under the wash sales rule, taxpayers cannot deduct a loss on the sale of stock or securities if the taxpayer purchases the same or substantially similar assets a short time before or after the sale that triggered the loss....more

Whitman Legal Solutions, LLC

How Struggling Orchestras are Like Qualified Opportunity Zone Funds

Symphony orchestras are important to their communities and to developing young talent, but they are struggling. Perhaps it’s no coincidence that the downtown areas of many cities also struggle to remain vital, as they...more

Eversheds Sutherland (US) LLP

Spinning in circles, Treasury resumes original course on regulated investment company income rules

On March 19, 2019, the Internal Revenue Service (IRS) and Treasury Department (Treasury) issued final regulations (T.D. 9851) (Final Regulations) under section 851 addressing the income test applicable to regulated investment...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Initial Takeaways on Clarification of Definition of "Specified Service Trade or Business"

Since the passage of the Tax Cuts and Jobs Act, business owners and tax practitioners alike have focused on the potential effect of Section 199A. Though it has been clear for some time that the 20% deduction afforded to...more

Orrick, Herrington & Sutcliffe LLP

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

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On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Proskauer Rose LLP

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer Rose LLP on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385. The final and temporary regulations recharacterize certain debt instruments as equity for...more

McDermott Will & Emery

New York ALJ Rejects Retroactive Application of Statute

State courts generally have allowed legislatures a fair amount of flexibility in adopting retroactive statutes, but a recent New York case held that, under the circumstances presented, the retroactive application of a statute...more

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