On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
Per recent transitional guidance, the IRS will not require taxpayers to report transactions involving receipt of digital assets under Section 6050I....more
The US Internal Revenue Service (IRS) has updated the Internal Revenue Manual (IRM) to specify which forms taxpayers can electronically sign and which types of electronic signatures are permitted, now on a permanent basis....more
The Internal Revenue Service (IRS) recently released proposed regulations regarding broker reporting for digital assets, including expansions of and additions to certain definitions, rules, and requirements. The IRS seeks...more
The Internal Revenue Service (IRS) recently ruled that if a taxpayer using a cash method of accounting stakes certain cryptocurrency and receives additional units of such cryptocurrency as rewards for staking, the taxpayer...more
A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more
The IRS has effectively delayed the implementation of the new digital asset broker rules under Internal Revenue Code Sections 6045 and 6045A.
The US Treasury Department (Treasury) and Internal Revenue Service (IRS) recently...more
The US Internal Revenue Service has extended its temporary approval of accepting electronic or digital signatures on certain IRS forms until October 31, 2023, and has expanded the list of forms that may be signed...more
The US Internal Revenue Service (IRS) extended its temporary approval of accepting digital signatures on certain IRS forms until December 31, 2021 (see Memorandum NHQ-10-1220-000, the Memorandum). This Memorandum has also...more
The Biden-Harris administration on April 28 introduced the American Families Plan (AFP), a $1.8 trillion legislative framework including provisions to “grow the middle class, expand the benefits of economic growth to all...more
5/3/2021
/ Biden Administration ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Net Investment Income ,
Tax Credits ,
Tax Rates ,
Tax Reform
The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more
The US Internal Revenue Service (IRS) issued news release IR-2020-194 on August 28, approving the temporary use of digital signatures for certain IRS forms that must be filed with the IRS manually. ...more
The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts sports owners, athletes, entertainers, and others in these industries to the...more
The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more
The US Internal Revenue Service (IRS) issued proposed regulations on May 7 that would expand tax withholding and reporting requirements in certain sales or exchanges of interests in partnerships engaged in one or more US...more
The Internal Revenue Service issued new instructions for the Employer Identification Number application process in December 2017. Unless an applicant is a government entity, the applicant’s “responsible party” must now be an...more