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Income Taxes › Investment

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Gerald Nowotny - Law Office of Gerald R....

Knowing Me, Knowing You! Using Private Derivatives in Personal Tax Planning

Gerald Nowotny - Law Office of Gerald R.... on

I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more

Morgan Lewis

Government Draft of Annual Tax Act 2024 Adopted

Morgan Lewis on

The Federal Cabinet adopted the government draft of an Annual Tax Act 2024 (JStG 2024) on June 5, 2024. The government draft largely corresponds to the draft bill of May 17, 2024 and contains a large number of very different...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Allen Barron, Inc.

The Tax Consequences of Offshore Mutual Funds for US Expats and Taxpayers

Allen Barron, Inc. on

What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more

Rivkin Radler LLP

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on

Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

Allen Barron, Inc.

When is a US Taxpayer Required to Disclose Offshore Accounts on an FBAR and Form 8938

Allen Barron, Inc. on

When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more

Cadwalader, Wickersham & Taft LLP

Should I Stay or Should I Go? Hedge Funds: Crypto and State Tax

Cadwalader, Wickersham & Taft LLP on

Hedge fund managers have a state tax gating issue when it comes to adding crypto to their assets under management. Generally, states such as New York, Connecticut and California encourage asset managers to locate in their...more

Rivkin Radler LLP

“C’mon Man! Tax the Rich!” Business Owners Face Tax Increases*

Rivkin Radler LLP on

Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more

International Lawyers Network

Establishing a Business Entity in Malta (Updated)

International Lawyers Network on

Introduction - With its corporate laws based upon those of the UK, Malta has incorporated laws and principles into its own legislation, providing comfort and security to the commercial and business community. The most...more

Bilzin Sumberg

US-Chile Income Tax Treaty Enters Into Force

Bilzin Sumberg on

On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more

Allen Barron, Inc.

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Orrick, Herrington & Sutcliffe LLP

Zukunftsfinanzierungsgesetz und ESOPs – Wirklich der große Wurf?

Orrick, Herrington & Sutcliffe LLP on

Wichtiger Hinweis: Die folgenden (rechtlichen) Ausführungen dienen nur der allgemeinen Information, sind nicht abschließend und stellen keine rechtliche, steuerrechtliche oder sonstige Beratung dar. ...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Allen Barron, Inc.

The High IRS Tax Rates on a Foreign Trust

Allen Barron, Inc. on

Are you concerned about the high IRS tax rates on a foreign trust? It is important to understand the tax and reporting consequences on this specific type of investment. It may very well be time to evaluate the net value of...more

Perkins Coie

Washington Court of Appeals Limits B&O Tax Deduction for Investment Income

Perkins Coie on

The Washington Court of Appeals has held that investment funds are subject to Washington state business and occupation (B&O) tax on their investment income. Although Washington law allows taxpayers to deduct “amounts derived...more

Cadwalader, Wickersham & Taft LLP

IRS Says Crypto Protocol Changes Are Not Taxable

Cadwalader, Wickersham & Taft LLP on

On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more

Seward & Kissel LLP

NFT Means Never Forget Taxes: Redux

Seward & Kissel LLP on

The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more

Cadwalader, Wickersham & Taft LLP

IRS Gets Serious About Digital Asset Reporting by Individuals

Cadwalader, Wickersham & Taft LLP on

Since 2019, Form 1040 has included a general question regarding the taxpayer’s cryptocurrency activity. Over the years, the IRS has modified the scope of its cryptocurrency inquiry. On the 2021 Form 1040, this question read:...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 21, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more

Walkers

Guernsey - Protected Cell Companies

Walkers on

Guernsey was the first jurisdiction to implement the protected cell company ("PCC"), doing so over 25 years ago. The PCC was originally created for use in insurance structures, although today it is also widely used for...more

McDermott Will & Emery

IRS Releases Memorandum on Deducting Cryptocurrency Losses

McDermott Will & Emery on

On January 13, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice Memorandum (CCA 202302011) concluding that taxpayers cannot claim a deduction for cryptocurrency losses that have, absent a sale or other...more

Cadwalader, Wickersham & Taft LLP

Back to the Future ... Cryptocurrency Tax Reporting

Cadwalader, Wickersham & Taft LLP on

The cryptocurrency industry may be breathing a sigh of relief following the release of recent IRS guidance on cryptocurrency tax reporting, which effectively postpones the January 1, 2023 effective date of the digital asset...more

Rivkin Radler LLP

Generating Tax Losses as a Hobby

Rivkin Radler LLP on

Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more

Polsinelli

Big Win for Investors Facing Listed Transaction Penalties for Conservation Easements

Polsinelli on

On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more

McDermott Will & Emery

Weekly IRS Roundup November 7 – November 11, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 7, 2022 – November 11, 2022....more

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