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IRS Issues Proposed Regulations Relating to Digital Asset Transactions

The U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) recently released proposed regulations (REG-122793-19) pertaining to information reporting and backup withholding, as well as basis and...more

Summary of Certain Business Tax Provisions in the Consolidated Appropriations Act, 2021

After much political gridlock, Congress passed an omnibus government-spending bill (Appropriations Act), which includes another COVID-19 relief package. The Appropriations Act contains many tax-related provisions. Some of the...more

IRS Publishes Proposed Regulations Applicable to Three-Year Carried Interest Holding Period Requirement

08.05.2020 | Updates On Friday, July 31, 2020, the Internal Revenue Service (IRS) issued proposed regulations under Section 1061 of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and Jobs Act, Section 1061...more

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

Don’t Burst My Bubble! IRS Provides Clarity for F Reorganizations

Recently, the Internal Revenue Service issued final regulations addressing reorganizations, commonly referred to as “F reorganizations,” under Section 368(a)(1)(F) of the Internal Revenue Code (the Code). F reorganizations...more

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