Berman v. Comm’r, released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more
In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more
7/18/2024
/ Cryptocurrency ,
Digital Assets ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Popular ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Liability ,
Tax Planning ,
Tax Reform
The Supreme Court has just weighed in on how gift and estate taxes apply with respect to non-cash gifts in Estate of Connelly v. United States. The Court’s opinion closely follows the economics of such arrangements, but...more
6/21/2024
/ Business Succession ,
Buy-Sell Agreements ,
Closely Held Businesses ,
Connelly v United States ,
Estate Planning ,
Estate Tax ,
Fair Market Value ,
IRS ,
Life Insurance ,
Redemption Agreement ,
SCOTUS ,
Shareholders ,
Tax Liability
On May 22, 2024, the US Department of Treasury and the IRS issued two important notices—one delaying the full implementation of the withholding rules on dividend equivalent payments, and the other on derivative reporting for...more
In 1989’s Bill & Ted’s Excellent Adventure, Keanu Reeves plays a stoner who gets caught up in historical shenanigans. By 2014, Mr. Reeves progressed past his teenage high jinks to become a James Bond-like action hero in his...more
5/23/2024
/ Cannabis Products ,
Cannabis-Related Businesses (CRBs) ,
Controlled Substances ,
Controlled Substances Act ,
Decriminalization of Marijuana ,
Dispensaries ,
IRS ,
Marijuana ,
Marijuana Related Businesses ,
Retail Market ,
Tax Liability ,
Tax Planning ,
Tax Refunds
On April 24, 2024, the Treasury Department and the IRS released final regulations under Section 897 that change the rules for determining whether qualified investment entities (QIEs) are domestically controlled under the...more
5/2/2024
/ C-Corporation ,
FIRPTA ,
Foreign Ownership ,
Internal Revenue Code (IRC) ,
IRS ,
New Regulations ,
Pension Funds ,
Public Entities ,
Qualified Investment Funds (QIFs) ,
REIT ,
U.S. Treasury
In March 2024, the Internal Revenue Service (“IRS”) released a new revision to Form W-9. Forms W-9 previously provided or collected do not expire nor need to be refreshed due to the publication of the new revision....more
3/19/2024
/ Business Ownership ,
Domestic Partnership ,
Federal Taxes ,
Foreign Partner ,
Form W-9 ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Ownership Interest ,
Partnerships ,
Required Forms ,
Tax Planning
The new rules address a number of issues that investors and sponsors were waiting for guidance on. The IRS has promised further guidance to address issues that remain in need of clarification.
...more
10/24/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury