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Capital Gains

Latham & Watkins LLP

The Corporate AMT’s Crypto Problem Poses Constitutional Hazards

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Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more

Stikeman Elliott LLP

Prorogation of Parliament and the Proposed Capital Gains Inclusion Rate Increase

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On January 6, 2025, Prime Minister Justin Trudeau announced his resignation as prime minister and the prorogation of Parliament until March 24, 2025. At the federal level, prorogation is an act by the Governor General,...more

Mayer Brown

Going in Circles: The IRS Limits Puerto Rico Source Rules in Responding to Aggressive Tax Positions

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The tax advantages for US individuals who become bona fide residents of US possessions can be substantial. These tax advantages have lured more than a few taxpayers to take unreasonably aggressive positions that they are...more

Davis Wright Tremaine LLP

Food Venture Financing News - Weekly Issue No. 217

Food Venture Financing Trends - Nexus W2V, a sustainable waste-to-value startup, announced that it raised $140 million in investments....more

Alston & Bird

IRS Releases New Section 83(b) Election Form

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Our Federal Tax Group explains the new standardized Form 15620 that taxpayers can use when receiving property that is subject to a “substantial risk of forfeiture.”...more

Goodwin

A New Form Section 83(b) Election: IRS Form 15620

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As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more

Foster Garvey PC

What Is Likely the Last Chapter in the Wild Journey of the Washington State Capital Gains Tax Occurred on November 5, 2024, With...

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The Wild Journey - I am taking time out from my multi-part series on Subchapter S to report on the Washington capital gains tax. As you know, I have reported in several prior blog posts on the numerous challenges...more

Mintz

Massachusetts Supreme Judicial Court Upholds Trustee’s Adjustment from Principal to Income

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Trustees have many duties, including the duty of loyalty, the duty to invest prudently, and the duty of impartiality to all beneficiaries. Trustees must also effectuate the wishes of the trust’s settlor. These duties often...more

Snell & Wilmer

IRS Releases Standardized Section 83(b) Election

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As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more

Barnea Jaffa Lande & Co.

New memorandum of law regulating the crypto sector in Israel

Barnea Jaffa Lande & Co. on

The Israel Tax Authority and the Ministry of Finance have published a memorandum of law to regulate the digital asset sector in Israel. This memorandum recognizes digital assets for the first time as capital assets subject to...more

Rivkin Radler LLP

Abandoning N.Y. Domicile – Must the Business Owner Abandon Their N.Y. Business?

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During the weeks leading up to the Presidential election, the media carried stories about wealthy supporters from each Party who had announced their intention to leave the country if the other Party’s candidate became...more

Cadwalader, Wickersham & Taft LLP

Shrinking Carried Interest Loophole Under Attack Again

On October 10, Representative Matt Cartwright (D-PA) introduced the Bill Pascrell Ending Tax Giveaway Act with the goal of “closing the controversial carried interest loophole.”...more

Stark & Stark

Dividing Cryptocurrency in a New Jersey Divorce: What You Need to Know

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Cryptocurrency has become an increasingly popular investment and asset class in recent years. As digital currencies like Bitcoin, Ethereum, and others continue to gain mainstream acceptance, they are also becoming more common...more

Lowenstein Sandler LLP

Real Estate Investing: The Tax Perspective

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Today on “Terra Firma: Conversations on Commercial Real Estate,” hosts Stacey Tyler and Stephen Tanico talk with tax attorneys and Lowenstein colleagues Sophia Mokotoff and Matthew F. Cammarata about important tax issues to...more

McNees Wallace & Nurick LLC

83(b) Elections Made Easy: Understanding the New IRS Form 15620

The Internal Revenue Service (IRS) has recently released a new form, 15620, which will significantly impact the way taxpayers report certain transactions in relation to Section 83(b) elections....more

Orrick, Herrington & Sutcliffe LLP

Employee Participation: Profit Participation Rights (#Genussrechte) – tax attractive alternative to VSOPs?

Profit participation rights are not yet the first choice for incentivizing employees of an exit-driven startup by allowing them to participate in the future success of the startup. However, they offer a more favorable...more

Proskauer - Tax Talks

Taxing carried interest in the UK: the new regime announced in the Labour government’s Autumn Budget 2024

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On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more

Morrison & Foerster LLP

UK’s Carried Interest Tax Hike and More Changes Proposed for Fund Managers in 2026

The Chancellor of the Exchequer, Rachel Reeves, delivered her first Budget Statement on 30 October. The Autumn Budget drew widespread attention, with several measures grabbing the headlines, including the historic fact that...more

Schwabe, Williamson & Wyatt PC

Election Day – OR and WA Statewide Measures: Mixed Tax Results

With more than half of the vote counted in Oregon and Washington, here are the initial results of statewide measures we have been tracking this election cycle. Oregon Measure 118 (Raising Corporate Taxes) – Defeated ...more

Goodwin

Key Takeaways from the Autumn Budget 2024

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Rachel Reeves, the first female Chancellor of the Exchequer in the role’s 800-year history, delivered Labour’s first budget in 14 years on the 30th October. We have set out below a brief summary of some of the tax measures...more

BCLP

Autumn Budget 2024 - 10 Key Tax Points for Business

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Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more

Morgan Lewis

UK Government Updates Tax Regime for Carried Interest

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As part of the Autumn Statement, the UK government on 30 October 2024 announced a reform of its taxation of carried interest. This follows a call for evidence on the reform of the UK taxation treatment of carried interest in...more

Cadwalader, Wickersham & Taft LLP

The UK Government’s Autumn Budget 2024

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2024 on 30 October 2024. The Budget was the first to be delivered by the new Chancellor of the Exchequer, following the election of the Labour...more

Dechert LLP

Labour Budget 2024: Reforms to the Taxation of Carried Interest

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The Chancellor of the Exchequer, Rachel Reeves MP, presented her first Budget to Parliament on 30 October 2024. In it, she announced both tax rate increases and also proposals which would fundamentally change the tax...more

BCLP

Autumn Budget 2024 - What’s the Tax Impact on the Real Estate Sector?

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The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more

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