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ASKramer Law

Business Taxation of Hedging Transactions Part V: Consolidated Groups

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Do the tax hedge rules apply to consolidated tax groups? Yes. The Treasury Regulations treat members of a consolidated corporate group as divisions of a single entity. As a single entity, the risks and positions of all group...more

Davies Ward Phillips & Vineberg LLP

Federal Budget 2024: How It Impacts You and Your Business

On April 16, 2024 (Budget Day) the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2024). Budget 2024 included a number of proposed...more

DarrowEverett LLP

How Bonus Depreciation Can Be A Timely Tool in Real Estate Deals

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So, you’re a real estate investor accustomed to tax mitigation strategies and you are starting to think about your next big project. With that comes so many streams of thought — location, timing, interest rates, partnerships,...more

K&L Gates LLP

New Washington Capital Gains Tax Impacts Estate Planning

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The Washington Supreme Court recently upheld as constitutional the state’s capital gains tax (WA Cap Gains Tax) that was enacted in 2021. The new WA Cap Gains Tax creates new wrinkles and provides new planning opportunities...more

Foster Garvey PC

When It Rains, It Pours in Washington State – The Washington Supreme Court Upholds the 2021 Enacted Capital Gains Tax

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It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more

Miller Nash LLP

Today in Tax: Digital Assets in Mergers & Acquisitions—Three Things Every Seller Should Know

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Acquisitions in industries related to cryptocurrency and blockchain technology exploded in 2021 in comparison with the preceding two years. Early data suggest that 2022 will be another record year for these acquisitions. This...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Kohrman Jackson & Krantz LLP

New Crypto Reporting Requirements Aim to Address Tax Gap

As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more

Dechert LLP

Cryptocurrency Stakeholders Should Prepare for Increased Tax Enforcement

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As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more

Rivkin Radler LLP

Selling to Private Equity? Maybe You Should “F Reorg” First

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Having Fun? Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more

Rivkin Radler LLP

The 2022 Federal Budget, Including Tax Changes – Are We There Yet?

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It Seemed Like a Good Idea- In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more

BCLP

Impact of UK Autumn Budget on real estate sector

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It was a relatively light Budget for the real estate sector. Highlights included the long-awaited announcement of the rate of the residential property developer tax and some reform of business rates....more

Rivkin Radler LLP

Tax Hikes, Senator Manchin, and Effective Dates – OH MY!

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What was your month like? If you’re a transactional professional – a class in which I include those who advise clients on the purchase and sale of businesses and investment assets, as well as those who assist clients in...more

Verrill

House Democrats Propose Estate and Gift Tax Law Changes: Important Estate Planning Implications

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What you need to know: On September 13, 2021, the House Ways and Means Committee released its proposed tax plan to fund President Biden’s $3.5 trillion “Build Back Better” social and economic spending package. If enacted as...more

Gould + Ratner LLP

New Tax Bill Puts a Stop to Incentives for Startup Investing

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Proposal’s Effect Would Limit Access to Capital for Small Businesses - An overlooked provision of the new, sweeping tax bill currently under consideration by Congress as part of President Joe Biden’s $3.5 trillion...more

Rivkin Radler LLP

Tax Hikes, Effective Dates, And Selling a Business

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Living the Dream- “How was your weekend?” Thank you for asking. Awful. “Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress. When the reconciliation budget...more

Chambliss, Bahner & Stophel, P.C.

Tax and Estate Planning for Cryptocurrency

In the past year, the global market capitalization of cryptocurrency has grown exponentially, reaching a high of $2.56 trillion on May 11, 2021. Coinbase, the largest cryptocurrency exchange, has more than 68 million verified...more

Rivkin Radler LLP

Increased Capital Gain Rate, Nonresident Aliens, And ESBTs

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Compare and Contrast- Have you spoken to anybody about the infrastructure bill on which the Senate is about to vote? I know I haven’t, except to explain that Speaker Pelosi has stated the House will not consider the bill...more

Foodman CPAs & Advisors

The IRS Is Cracking Down On Cryptocurrency Tax Reporting

If you’ve engaged in cryptocurrency or other virtual currency transactions worth $20,000 in any one year between 2016 and 2020, the IRS wants to hear from you. The IRS believes thousands of taxpayers are not telling the...more

Rivkin Radler LLP

Bona Fide Intercompany Loan – Are You Sure?

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Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more

Rivkin Radler LLP

Tax Increases In Sight? Time To Sell The Business? Focus On Economics

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Not Good- As Mr. Biden settled into the White House, and as the Democrats began planning how to best utilize their slim Congressional majority to enact and pay for their sweeping legislative agenda, the principal concern...more

Husch Blackwell LLP

Biden's Green Book Includes Retroactive Capital Gains Tax Increase

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On Friday, May 28, 2021, the Biden Administration released its Green Book setting out the President’s revenue and policy proposals. Of particular interest to investors is the administration’s proposal to raise the tax on...more

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

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Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

Rivkin Radler LLP

Biden’s Proposed Income Tax Increases And The Sale Of The Baby Boomer Business

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“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more

Whitman Legal Solutions, LLC

Re-Evaluating Real Estate Dispositions Under the Biden Tax Plan

How Real Estate Investment is Like Buying Violins - Real estate investors also frequently gradually increase in size and price of their assets. A real estate investor might start small with a single duplex. When they sell...more

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