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Capital Losses Tax Planning

ASKramer Law

Taxation of Foreign Currency Transactions Part V: Hedged Executory Contracts

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What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more

ASKramer Law

Taxation of Foreign Currency Transactions Part IV: Hedging & Section 1.988-5(a) Debt Hedges

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Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more

ASKramer Law

Taxation of Foreign Currency Transactions Part III: Section 988 Transactions Defined, Character & Source

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Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more

ASKramer Law

Taxation of Foreign Currency Transactions Part II: Gains, Losses, Personal Transactions, and Electing Out of Section 988

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Are all foreign currency gains taxable? No. Under a de minimis exemption individual taxpayers with foreign currency gains of $200 or less on a “personal transaction” do not need to report them....more

ASKramer Law

Taxation of Foreign Currency Transactions Part I: Definitions and Rules for Taxing Foreign Currencies

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Navigating the federal taxation of foreign currency can be compared to trying to cross a perilous sea. Both involve unexpected rough patches, serious difficulties, and frustrating complexity....more

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

ASKramer Law

Business Taxation of Hedging Transactions Part III: Identification Requirements and Aggregate Hedging

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When must a hedge be identified and accounted for tax purposes? Taxpayers must identity each hedging transaction and the item it hedges. A taxpayer must clearly identify a hedging transaction “before the close of the day on...more

ASKramer Law

Business Taxation of Hedging Transactions Part II: Common Situations

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What is the “tax character” of a hedge? A taxpayer receives ordinary gain or loss on qualified hedges that have been properly identified in accordance with Treasury Regulation § 1.1221-2. This allows a taxpayer to ensure that...more

ASKramer Law

A Comprehensive Guide to the Deductibility of Digital Asset Losses

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In November 2023, almost 11,000 cryptocurrencies and digital tokens were listed on CoinMarketCaps.com. In addition, tens of thousands of non-fungible tokens (NFTs) are sold daily on various crypto exchanges and NFT platforms....more

ASKramer Law

Hedging: Inadvertent Errors and Tax Identification

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Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

Troutman Pepper on

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Cadwalader, Wickersham & Taft LLP

FTX Tax Losses: The Land of Misfit Toys

Reportedly, there are over a million creditors in the bankruptcy of the cryptocurrency exchange FTX and its affiliated entities. A substantial number of these FTX creditors may include U.S. retail customers who held and...more

Freeman Law

Tax Court in Brief | Powell v. Comm’r | IRS Forms vs. Statutes – Net Capital Loss Deduction

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Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

Freeman Law

Tax Court in Brief | Musselwhite v. Commissioner | Loss in Sale of Real Estate: Ordinary Loss or Capital Loss?

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Tax Litigation:  The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Spencer v Commissioner, T.C....more

Bowditch & Dewey

Massachusetts Taxpayers Find More Complexity in Differences Between Massachusetts and Federal Tax Law

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It seems every year there are changes to the Internal Revenue Code (IRC). It is a challenge, even for tax pros, to keep up with the ever-changing tax code. Massachusetts taxpayers also have an added challenge in keeping up...more

Freeman Law

The Tax Court in Brief - August 2021 #3

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 9 – August 13, 2021 - Manuelito B. Rodriguez &...more

Bowditch & Dewey

What You Should Know About Day Trading

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Since the start of the global pandemic this past March, day trading has become a way for some to spend their newfound free time while quarantining at home. For others, day trading has filled the void that was left when sports...more

McDermott Will & Emery

Weekly IRS Roundup May 6 – 10, 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 May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more

Bowditch & Dewey

Massachusetts Tax Deduction for Gambling Losses

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Since the MGM casino opened in August, gamblers have reportedly wagered more than $428 million on MGM Springfield’s slot machines that generated about $40 million in revenue for MGM and reportedly another $18.5 million in...more

Orrick, Herrington & Sutcliffe LLP

IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

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