News & Analysis as of

Future Tax Treatment Internal Revenue Service

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

Federal Tax Treatment of Amounts Paid Toward the Purchase of Energy Efficient Property/Improvements Under Department of Energy...

The United States Internal Revenue Service (“IRS”) issued Announcement 2024-19 titled: Federal Tax Treatment of Amounts Paid Toward the Purchase of Energy Efficient Property and Improvements Under Department of Energy...more

Hinckley Allen

Converting an LLC to an S Corporation: A Mistake Waiting to Happen

Hinckley Allen on

Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more

ASKramer Law

Hedging: Inadvertent Errors and Tax Identification

ASKramer Law on

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

Cadwalader, Wickersham & Taft LLP

Staking Rewards: Is IRS Digging In or Changing Its Mind?

Crypto industry groups had hoped to use the tax refund case of Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.) as the vehicle to prove that staking rewards received by a crypto validator only trigger gain upon the...more

Foodman CPAs & Advisors

Upcoming Virtual Currency FBAR and FATCA Reporting Enforcement

Under current FinCEN regulations, a foreign account holding virtual currency is not reportable on the FBAR.  However, FinCEN in its FinCEN Notice 2020-2, proposes amending reports of foreign financial accounts (FBAR)...more

Groom Law Group, Chartered

Direct Primary Care Arrangements and Health Care Sharing Ministries Receive Favorable Tax Treatment Under Proposed Regulations

On Monday, June 8, 2020, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) released Proposed Regulations addressing the tax treatment of amounts paid for two unique types of medical arrangements –...more

Polsinelli

Stick a Fork in It? IRS Issues Updated Guidance on the Tax Treatment of Cryptocurrency Forks and Provides Answers to a List of...

Polsinelli on

Five years or so years ago, the Internal Revenue Service (“IRS”) provided its first, and until this week, only formal advice on the taxation of cryptocurrency transactions in Notice 2014-21. This guidance, while helpful in...more

Foodman CPAs & Advisors

Taxpayers that have VIRTUAL CURRENCY held in a Centralized Virtual Currency Exchange outside the U.S must file an FBAR and FORM...

On May 30, 2018, the AICPA (American Institute of Certified Public Accountants) wrote a letter to the IRS to obtain further definition and clarity regarding Virtual Currency (VC) FATCA and FBAR reporting requirements....more

Foodman CPAs & Advisors

AICPA steps up to IRS to recommend that IRS provide Virtual Currency Clarity

On 5/30/18, the American Institute of CPAs (AICPA) sent a letter (https://www.aicpa.org/content/dam/aicpa/advocacy/tax/downloadabledocuments/20180530-aicpa-comment-letter-on-notice-2014-21-virtual-currency.pdf) to the IRS...more

Ballard Spahr LLP

IRS Eases Rules for Plan Loans and Hardship Distributions After Hurricane Harvey

Ballard Spahr LLP on

The IRS has released Announcement 2017-11 to provide relief to taxpayers from requirements for loans and hardship distributions for participants of qualified retirement plans who have been adversely affected by Hurricane...more

McDermott Will & Emery

IRS Issues Guidance on Tax Treatment of Energy Savings Performance Contracts

On January 19, 2017, the Internal Revenue Service (IRS) issued Rev. Proc. 2017-19, 2016-6 I.R.B. (the Rev. Proc.), providing a safe harbor under which it will not challenge the tax treatment of an Energy Savings Performance...more

Troutman Pepper

IRS ‘Repairs’ The Examination Of Tangible Property Regulation Issues

Troutman Pepper on

In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more

Hinshaw & Culbertson LLP

Representations Of Future Tax Treatment To Induce Creation Of Pension Plan Are Not Actionable As A Matter Of Law

The California Fourth District Court of Appeal adopted the principle that it is inherently unreasonable for any person to rely on a prediction of future IRS enactment, enforcement, or non-enforcement of the law by someone...more

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