News & Analysis as of September 18, 2024

Net Investment Income

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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 -

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

Perkins Coie on 8/7/2023

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

Weekly IRS Roundup September 12 – September 16, 2022

McDermott Will & Emery on 9/20/2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022...more

NIIT Expansion Under Proposed Build Back Better Act Includes Subtle Tax Increase on Sales of Private Businesses

Stinson LLP on 12/7/2021

In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...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

The Tax Court in Brief - August 2021 #4

Freeman Law on 9/10/2021

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 16 – August 20, 2021 - Catlett v. Comm’r, No....more

Are The Feds Getting Ready To Kick Your “S”?

Rivkin Radler LLP on 8/30/2021

Report Card- A couple of weeks ago, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report that presented the results of its review to determine whether the IRS’s “policies, procedures and,...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

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on 5/25/2021

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Tax Reform in the American Families Plan

Morgan Lewis on 5/3/2021

The Biden-Harris administration on April 28 introduced the American Families Plan (AFP), a $1.8 trillion legislative framework including provisions to “grow the middle class, expand the benefits of economic growth to all...more

How Dealings Between Related Parties Doomed A Captive Insurer

Farrell Fritz, P.C. on 3/17/2021

Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

Estate and Trust Planning Opportunity – The 65 Day Rule

Dickinson Wright on 2/18/2019

It is not is too late to plan for 2018. Under Section 663(b) of the Code, the “65 Day Rule” provides an opportunity for estates and certain trusts to elect to treat distributions made within 65 days of year-end as if made on...more

Treasury Green Book Proposals — Private Foundations

Bryan Cave Leighton Paisner on 3/9/2016

The Department of the Treasury has released the Treasury Green Book for Fiscal Year 2017, which provides explanations of the President’s budget proposals. One such proposal (remember…these are just proposals, not actual...more

U.S.Tax Court Decision May Allieviate The 3.8% Net Investment Income Tax Burden For Many Trusts

BakerHostetler on 4/1/2014

Because trusts are subject to the 3.8% Net Investment Income Tax at a very low income level, $12,150 for 2014, trustees of trusts owning interests in operating entities have been considering ways to meet the material...more

FBAR and Form 8938 Assistance Provided by Treasury

Holland & Knight LLP on 1/30/2014

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

MoFo New York Tax Insights - Volume 6, No. 4 - January 2014

Morrison & Foerster LLP on 1/27/2014

In This Issue: FATCA Developments: Treasury Signs IGAs; IRS Finalizes FFI Agreement; IRS Releases Final and New Proposed “Dividend Equivalent” Regs; IRS Issues Final Swap Assignment Regs; IRS Issues Final “Net...more

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