News & Analysis as of

Capital Gains Tax Code

Goulston & Storrs PC

New Bill Will Tax Real Estate “Promote” as Carried Interest Subject to Three-Year Holding Period

Goulston & Storrs PC on

Senators Manchin and Schumer this week announced that the “Inflation Reduction Act of 2022” will be added to the FY2022 Budget Reconciliation bill. The bill includes changes to Section 1061 of the Code (which was added to the...more

Rivkin Radler LLP

The Tax-Deferred Rollover – Some Considerations

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“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more

Rivkin Radler LLP

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

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Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

McDermott Will & Emery

How to Invest in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Cadwalader, Wickersham & Taft LLP

IRS Proposes Carried Interest Regulations

On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Following Up On "Election Day is Coming – Will Major Tax Changes Follow?

On August 10, 2020, we published a post outlining some of President Biden’s tax proposals set forth on the campaign trail. This post takes a deeper look at some of those proposals and some of the factors likely to influence...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

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Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Fenwick & West LLP

Qualified Small Business Stock: Common FAQs by Startup Founders and Investors

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We receive many questions from founders, investors and others about qualified small business stock. And it’s no wonder, given the complexity of the concept. In this article, we provide a high-level overview of QSBS. A...more

Lowndes

Important Year End Deadline for Opportunity Zones

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Opportunity zones provide a powerful tool for taxpayers to defer recognizing their capital gains if they roll over their investment into a qualified opportunity zone fund, and offer investors the potential of avoiding...more

Dechert LLP

Investment Funds Update – Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Dechert LLP on

Money Market Funds - The AMF published a guide describing the main impacts of the application of the MMF Regulation, as well as the details of the authorization procedures specific to such money market funds, notably...more

Brooks Pierce

Investing In Qualified Opportunity Funds

Brooks Pierce on

The Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more

Holland & Knight LLP

Opportunity Zone Investments: What You Need to Know and Potential Scenarios - A New Opportunity for Investors to Defer Taxable...

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• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more

Morgan Lewis

Kazakhstan Adopts New Tax Code

Morgan Lewis on

The code includes some key changes in the taxation of dividends, interest, and capital gains....more

Holland & Knight LLP

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

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Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

Orrick, Herrington & Sutcliffe LLP

Carried Interest tax regime in Italy (art. 60 of Law 96/2017)

The new tax regime aims at discounting the taxation of the excess profit (i.e. profit in excess of the amount that the managers have contributed to the undertaking) attributed to investment managers or managers of target...more

Carlton Fields

U.S. Pre-Immigration Tax Planning

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The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

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