News & Analysis as of September 19, 2024

Investment Adviser

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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 -

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on 5/6/2024

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

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

Tokenization Lawyer – 5 Reasons Why You Might Need One

Oberheiden P.C. on 5/17/2022

What is Tokenization? Tokenization is the process of converting an asset into a token on the blockchain. It operates by dividing—or fractionalizing—the ownership of an asset (whether the asset is a piece of real estate or...more

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

Neal, Gerber & Eisenberg LLP on 8/25/2020

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

Developments in Cryptocurrency in 2018

Akin Gump Strauss Hauer & Feld LLP on 9/24/2018

• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more

Personal Planning Strategies - September 2018

Proskauer Rose LLP on 9/10/2018

With over a century of combined experience, the lawyers of Proskauer's Private Client Services Department regularly provide their diverse clientele – from business entrepreneurs and corporate executives to sports figures and...more

Investment Management Update

Ballard Spahr LLP on 12/15/2016

IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more

Wealth Management Update - August 2015

Proskauer Rose LLP on 8/3/2015

August Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The August § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager

Akin Gump Strauss Hauer & Feld LLP on 9/11/2014

On September 5, 2014, the Office of Chief Counsel, Internal Revenue Service (IRS) released an internal generic legal advice memorandum advising an IRS field agent that the statutorily provided “limited partner” exception to...more

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