Section 1402(a)(13) of the Internal Revenue Code provides that the distributive share of “limited partners, as such” from a partnership is not subject to self-employment tax.[1] Managers of private equity and hedge funds are...more
On December 28, 2022, the Internal Revenue Service (the “IRS”) and the Treasury Department released proposed regulations (the “Proposed Regulations”) under sections 892 and 897 of the Internal Revenue Code (the “Code”). If...more
IRS Commissioner Charles Rettig, testifying before Congress in April 2021, estimated the gap between taxes owed and taxes collected in the United States to be close to $1 trillion....more
3/4/2022
/ Bitcoin ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Financial Transactions ,
Income Taxes ,
IRS ,
Proposed Legislation ,
Regulatory Agenda ,
Reporting Requirements ,
Tax Liability ,
Tax Reform ,
Virtual Currency
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more
On October 7, 2020, the U.S. Internal Revenue Service (“IRS”) and Treasury Department released final regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more
8/10/2020
/ APIs ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Proposed Regulation ,
Recharacterization
On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more
The U.S. Internal Revenue Service (IRS) quietly added two new questions and answers regarding virtual currency donations to its answers to Frequently Asked Questions on Virtual Currency Transactions (FAQs) on December 26,...more
In October of 2019, the U.S. Internal Revenue Service issued the first new guidance on the taxation of cryptocurrency transactions in over five years (the “Guidance”). The Guidance comprising a revenue ruling (Rev. Rul....more
12/12/2019
/ Blockchain ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Guidance ,
Revenue Rulings ,
Tax Cuts and Jobs Act ,
Virtual Currency
The first official guidance on the taxation of cryptocurrency transactions in more than five years has been issued.
The guidance includes both a Revenue Ruling (Rev. Rul. 2019-24, 2019-44 I.R.B. 1) and answers to...more
10/18/2019
/ Blockchain ,
Capital Gains ,
Cryptocurrency ,
Distributed Ledger Technology (DLT) ,
Ether ,
Ethereum ,
Fair Market Value ,
Income Taxes ,
IRS ,
New Guidance ,
Peer-to-Peer ,
Revenue Rulings ,
Transfer Taxes ,
Virtual Currency
Implements 2018 Proposed Regulations, ending most limitations on investments in U.S. property, as well as pledges and guarantees by CFCs wholly-owned by U.S. corporations – also provides PTI guidance for CFC...more
5/31/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Distribution Rules ,
Final Rules ,
Financial Guarantee Requirements ,
IRS ,
Multinationals ,
New Regulations ,
Section 956 ,
Stocks ,
Tax Cuts and Jobs Act ,
Voting Shares
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code on dispositions...more
5/23/2019
/ FIRPTA ,
Foreign Persons ,
Income Taxes ,
International Tax Issues ,
IRS ,
K-1 ,
Partnerships ,
Proposed Regulation ,
Reporting Requirements ,
Shareholders ,
Withholding Requirements
On March 4, 2019, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (the “Treasury”) released proposed regulations (the “Proposed Regulations”) regarding the deduction for “foreign-derived intangible...more
4/23/2019
/ Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Reform
On January 18, 2019, the U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (the “Final Regulations”) regarding the “passthrough deduction” for qualified trade or...more
3/11/2019
/ Business Ownership ,
Final Rules ,
IRS ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Business Income ,
S-Corporation ,
Section 199A ,
Sole Proprietorship ,
Specified Service Trade Or Business (SSTB) ,
Tax Deductions ,
UBIA
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding...more
On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-67 (the “Notice”), addressing issues relevant to tax-exempt organizations arising under new Section 512(a)(6) of the Internal Revenue Code (the...more
9/5/2018
/ Controlled Foreign Corporations ,
GILTI tax ,
Income Taxes ,
IRS ,
NAICS ,
Partnerships ,
Public Comment ,
Reporting Requirements ,
Tax Exempt Entities ,
Tax Exemptions ,
UBTI