News & Analysis as of

Capital Gains New Guidance

BakerHostetler

IRS Issues Guidance on Non-Fungible Tokens What It Says and Does Not Say

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The IRS and Treasury Department announced on March 21, 2023, that they intend to issue guidance providing that certain NFTs qualify as collectibles under Section 408(m) of the Code. The Notice is the first guidance issued by...more

Jones Day

Cryptocurrency Tax Update: Impact of New IRS Guidance and Proposed U.S. Tax Rate Increase

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The IRS recently clarified its position on the U.S. income tax treatment of a hard fork. A hard fork occurs when protocols on a blockchain change, causing a "fork" or splintering of the existing blockchain into two distinct...more

Jackson Walker

Qualified Opportunity Zones COVID-19 Relief Extended

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On January 20, 2021, the Treasury Department published Notice 2021-10, extending COVID-19 relief for qualified opportunity funds (QOFs) and their investors. The new guidance generally extends the relief already in effect...more

Ruder Ware

Responding to the Pandemic, IRS Loosens Opportunity Zone Requirements

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The IRS recently offered relief to Qualified Opportunity Fund investors, waiving a penalty and pushing back some investment deadlines. This new guidance comes as investment in opportunity zones slows, stymied by brisk...more

Sullivan & Worcester

Opportunity Zone Best Practices – Not All Extensions are Automatic

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The IRS recently issued additional Opportunity Zone-related guidance, Notice 2020-39, that grants extension relief with respect to five specific time-sensitive actions. Among other things, Notice 2020-39 (i) allows certain...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Kramer Levin Naftalis & Frankel LLP

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

McDermott Will & Emery

Weekly IRS Roundup October 28 – November 1, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019. October 30, 2019: The IRS issued an Action on Decision in which...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Guidance Regarding Virtual Currency Transactions

On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more

Proskauer - Tax Talks

IRS answers some, but not all, questions in long-awaited cryptocurrency guidance

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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

Latham & Watkins LLP

The Future Ain’t What It Used to Be: New Tax Guidance Issued for Cryptocurrencies

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The IRS has published a Revenue Ruling and FAQs clarifying some long-standing virtual currency questions. On October 9, 2019, the US Internal Revenue Service (IRS) issued its first guidance on the tax treatment of...more

Fenwick & West LLP

IRS Issues Long-Awaited Cryptocurrency Guidance in Revenue Ruling 2019-24 and New FAQs

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On October 9, 2019, the IRS released Revenue Ruling 2019-24, which provides guidance with respect to hard forks and airdrops of cryptocurrency, and new frequently asked questions (FAQs), which provide guidance on other...more

Wilson Sonsini Goodrich & Rosati

IRS Issues Guidance for Transactions Involving Virtual Currency

On October 9, 2019, the Internal Revenue Service (IRS) issued Revenue Ruling 2019-24, which describes when a "hard fork" results in adverse tax consequences, and a set of frequently asked questions (the FAQs), which provide...more

Ballard Spahr LLP

Update on Qualified Opportunity Zones: Second Set of Guidance Issued

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OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more

Poyner Spruill LLP

OZ Update - The New Proposed Regulations Are Out - New Guidance on Eligibility for OZ Tax Benefits

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Last week, Treasury issued a second round of proposed regulations regarding Opportunity Zones?offering investors more clarity as to whether their investments in designated Opportunity Zones will qualify for current capital...more

UB Greensfelder LLP

IRS Issues Long-Awaited Second Round of Opportunity Zone Regulations

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As part of the 2017 Tax Cuts and Jobs Act, Congress added a new provision to the Internal Revenue Code allowing investors to defer capital gains by making investments into Qualified Opportunity Funds (QOFs). However, many...more

A&O Shearman

Opportunity Zones: Second Set of Proposed Regulations Provide Clarity

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On Wednesday, April 17, 2019, the Treasury Department and the Internal Revenue Service issued a broad, investment-friendly second set of Proposed Regulations (the “Proposed Regulations”) regarding “Qualified Opportunity...more

King & Spalding

IRS and Treasury Release Second Round of Qualified Opportunity Zone Guidance

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On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more

Brownstein Hyatt Farber Schreck

Will Opportunity Zones Succeed in Stimulating Investments?

Expectations are high this year for “Opportunity Zones” in the real estate industry. A product of the Tax Cuts and Jobs Act, Qualified Opportunity Zones (QOZs) are expected to be one of the biggest trends to impact real...more

Latham & Watkins LLP

IRS Issues Guidance on Transfers by Non-US Partners of Interests in Partnerships With US Assets

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Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or business. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Guidance for Opportunity Zone Funds Clarifies Important Issues, Leaves Door Open to Additional Guidance

The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update

Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more

Mintz

Land of Tax Opportunity Zones

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Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program - On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more

Steptoe & Johnson PLLC

IRS Publishes New Guidance on Opportunity Zones

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Observers of a new federal program received welcome news Friday, October 19, when the U.S. Treasury Department released long-anticipated guidance around Opportunity Zones, a program that will drive substantial private capital...more

Farella Braun + Martel LLP

Treasury Department Guidance Will Stimulate Opportunity Fund Investments

The Opportunity Zones Program (OZ Program) aims to infuse capital into low-income communities known as qualified opportunity zones (QOZs) by offering tax-advantaged investments benefiting electing Qualified Opportunity Fund...more

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