Memorandum to our Investment Management Clients and Friends -
The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more
12/5/2023
/ Audits ,
Cross Motions ,
Fund Managers ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Management ,
IRS ,
Limited Partnerships ,
Motion for Summary Judgment ,
Self-Employment Tax ,
Tax Court
The Corporate Transparency Act (the “CTA”), a set of new regulations being implemented by the Financial Crimes Enforcement Network (“FinCEN”), requires entities newly formed or registered to do business in the United States...more
12/4/2023
/ Beneficial Owner ,
Beneficiaries ,
Corporate Transparency Act ,
Criminal Penalties ,
Deadlines ,
Exemptions ,
FinCEN ,
Grantor Trusts ,
Investment Adviser ,
Investment Companies ,
Investment Funds ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
NDAA ,
Reporting Requirements ,
Trusts
August 22, 2023 Earlier this summer, the House Committee on Ways and Means introduced a tax relief package (the “Proposals”), which establishes a framework for potential tax changes. The Proposals are not expected to be...more
The IRS published guidance on the federal income tax treatment of staking income in Revenue Ruling 2023-14. Consistent with its prior ruling on hard forks, the IRS maintains that taxpayers realize taxable income when he or...more
The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more
This Memorandum discusses the New York City pass-through entity tax (“PTET”) election. Partnerships and S corporations with New York City resident partners, members or shareholders may elect into this tax. Once elected, New...more
This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more