News & Analysis as of September 25, 2024

Capital Gains Tax

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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 -

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

Allen Barron, Inc. on 5/31/2024

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

Earnouts and Their Tax Treatment

Venable LLP on 3/19/2024

As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on 2/5/2024

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

If It's Too Good To Be True...The Latest Guidelines from the IRS

Davidoff Hutcher & Citron LLP on 1/8/2024

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation. Almost all techniques that we use are incremental variations of an older technique...more

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on 11/16/2023

What are the most important elements of estate and tax planning for US expatriates? Are you planning to move out of the United States? Are you a US taxpayer who lives and works outside of the country? What are some of the...more

Tax Tips for Lottery Winners

Allen Barron, Inc. on 11/10/2023

Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion. Just over the $1.765 billion jackpot claimed last month (Oct 2023). What are some tax tips for lottery winners and...more

NFTs: A Tale of Two Classifications

Blank Rome LLP on 6/15/2023

On March 21, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS)” released Notice 2023-27, announcing their intent to provide guidance on classifying certain non-fungible tokens (“NFTs”) as...more

Cryptocurrency Wash-Sale Loss Harvesting

Bowditch & Dewey on 6/14/2023

The IRS wash-sale rule does not currently apply to cryptocurrency because the IRS considers virtual currencies to be property rather than securities. In general, a taxpayer who exchanges cryptocurrency for goods, services or...more

NFT Means Never Forget Taxes: Redux

Seward & Kissel LLP on 5/18/2023

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

BG Tax Alert - Take Two: Biden’s Budget Proposes Tax Hikes

Bailey & Glasser, LLP on 5/11/2022

On March 28, 2022, President Biden announced his 2023 federal budget (Budget), which is often referred to as the President’s Green Book. While much of the Budget harkens back to the “Build Back Better Framework” (Framework),...more

Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller

Jones & Keller, P.C. on 4/6/2022

High-net worth individuals have an opportunity to take advantage of high transfer tax exemptions if they act fast. Set to expire in 2026, unless Congress acts sooner, the time is now to implement strategies that make the most...more

Taking the Sting Out of “Death Taxes”

Jones & Keller, P.C. on 4/1/2022

There has been a lot of talk since September 2021 about the Build Back Better Act, which included some major tax increases. According to U.S. Senator Joe Manchin of West Virginia, this Act is dead—and I think that is the most...more

Washington’s New Capital Gains Tax is Overturned as Unconstitutional

Lasher Holzapfel Sperry & Ebberson PLLC on 3/7/2022

In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more

Taxation of Crypto Mining

Freeman Law on 1/27/2022

Amid the crypto boom, mining has become an extremely lucrative venture for many and critical to maintaining decentralized cryptocurrency networks. It is no surprise then that mining has been subject to IRS scrutiny and...more

Taxation of Crypto Margin Trading

Freeman Law on 1/17/2022

This year has been a banner year for cryptocurrencies, with the prices of Bitcoin and Ethereum reaching all-time highs in November. Undoubtably, margin trading – the borrowing of capital from a broker or a margin lender to...more

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

Rivkin Radler LLP on 11/23/2021

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

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on 10/15/2021

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Congress Readies New Round of Tax Increases

Freeman Law on 10/12/2021

The House Committee of Ways and Means (the “House”) has been busy the last few days. Indeed, the House continues to mark up and work through potential revenue raisers (i.e., tax increases) to help pay for recent legislative...more

Impact of House Ways and Means Tax Proposals for Trusts, Estates, and Retirement Accounts

Bowditch & Dewey on 9/29/2021

In this second blog post on the House Ways and Means Tax proposals, we address the proposed changes that will affect the taxation of trusts, estates, and retirement plans. As we discussed, on September 13, 2021, the...more

Impact of House Ways and Means Tax Proposal on Domestic Businesses

Bowditch & Dewey on 9/22/2021

On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more

Carried Interest Taxation: Update on Final Regulations and Potential Legislative Changes

Gray Reed on 9/14/2021

In January 2021, the U.S. Department of Treasury and the Internal Revenue Service released final regulations (the Final Regulations) under Section 1061 of the Internal Revenue Code of 1986, as amended (the Code). Code...more

Summary of Proposed 2021 Federal Tax Law Changes

Burr & Forman on 7/21/2021

President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on 6/7/2021

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Biden Administration aims to increase IRS enforcement against high earners and corporations

Hogan Lovells on 5/27/2021

A significant focus on tax compliance and follow-up enforcement actions may be on the horizon. We previously reported that the Internal Revenue Service (IRS) Cyber Crimes Unit had signaled its determination to increase...more

Tax Provisions of the American Families Plan

Proskauer - Tax Talks on 5/6/2021

On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten...more

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