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Income Taxes › Internal Revenue Service › Stocks

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 -
Bilzin Sumberg

A Transition to What? SCOTUS Set to Decide the Fate of IRC 965

Bilzin Sumberg on

The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more

McDermott Will & Emery

Weekly IRS Roundup December 19 – December 23, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 19, 2022 – December 23, 2022...more

McDermott Will & Emery

Weekly IRS Roundup March 6 – March 12, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 6, 2022 – March 12, 2022... March 6, 2022: The IRS issued a news release reminding...more

Farrell Fritz, P.C.

Sale Of Stock + Target’s Capitalized Costs = Creation Of Intangible? Nope

Farrell Fritz, P.C. on

Sale of Stock- Ask a business owner to identify the parties to an agreement for the purchase and sale of the stock of a target corporation, perhaps even their own. After giving you a quizzical look, they will likely reply...more

Orrick, Herrington & Sutcliffe LLP

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans (UPDATED)

Orrick, Herrington & Sutcliffe LLP on

Requirement to Report - For (1) any exercise of an incentive stock option (ISO) during 2019 or (2) transfer during 2019 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan (ESPP), the...more

Farrell Fritz, P.C.

Carried Interest, Qualified Small Business Stock, And Excluded Gain: So Happy Together?

Farrell Fritz, P.C. on

Water, Water Everywhere, Nor Any Drop to Drink- At the beginning of every week, after posting that week’s article, I start to think about a topic for the next post. There are times when I struggle to find something that...more

Farrell Fritz, P.C.

Selling S Corporation Stock – Are You Sure?

Farrell Fritz, P.C. on

Still a Valid S Corporation? Much has been written regarding the limitations of the S corporation, especially the requirement that it have only one class of stock, and the prohibition against its having nonresident aliens,...more

Holland & Knight LLP

New Treasury Regulations Revise Taxation of U.S. Persons Owning Foreign Corporations - Guidance Will Impact Minority Partners in...

Holland & Knight LLP on

Highlights - • In an unanticipated development, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) recently issued regulations (New Guidance) that significantly modifies the taxation of U.S....more

Fenwick & West LLP

IRS Issues New Guidance on Section 83(i)

Fenwick & West LLP on

The Internal Revenue Service issued Notice 2018-97 on December 7, providing initial guidance for the new Section 83(i) of the Internal Revenue Code (Section 83(i)) enacted by the Tax Cuts and Jobs Act. The notice principally...more

Fenwick & West LLP

The New Foreign Tax Credit Proposed Regulations – An Executive Summary

Fenwick & West LLP on

Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

Proskauer - Blockchain and the Law

Income, from Whatever Exchange, Mine, or Fork Derived: The Basics of U.S. Cryptocurrency Taxation

Proskauer - Blockchain and the Law on

In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more

Sheppard Mullin Richter & Hampton LLP

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

Troutman Pepper on

Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

Proskauer - Tax Talks on

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

Coblentz Patch Duffy & Bass on

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Snell & Wilmer

IRS Finalizes Regulations Simplifying 83(b) Filing Requirements

Snell & Wilmer on

On July 23rd of last year, I blogged on a set of proposed regulations eliminating the requirement that a taxpayer attach a copy of his or her Section 83(b) election to their individual tax return. This July, the IRS made the...more

Tucker Arensberg, P.C.

IRS Provides Guidance for Making an 83(b) Election

Tucker Arensberg, P.C. on

On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more

Polsinelli

Small Business Investors Can Save Big with New IRS Code Amendments

Polsinelli on

Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

Wilson Sonsini Goodrich & Rosati on

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

Latham & Watkins LLP

Treasury Targets Related-Party Debt with Proposed Regulations to Treat Debt as Equity

Latham & Watkins LLP on

Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt. On April 4, 2016, the US Department of the Treasury (Treasury) and the...more

Eversheds Sutherland (US) LLP

Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes

Eversheds Sutherland (US) LLP on

On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC § 385 (the Proposed Regulations) that are intended to combat perceived concerns associated with indebtedness between...more

Morrison & Foerster LLP

The Best of a Bad Investment

Morrison & Foerster LLP on

A recent tax case out of the Fifth Circuit approved a taxpayer’s strategy to make the best of a bad investment. According to the facts of Pilgrim’s Pride v Commissioner, the taxpayer purchased preferred stock from two...more

Morrison & Foerster LLP

Private Ruling Endorses Taxpayer-Friendly Reading of “Qualified Small Business” Under Section 1202

Morrison & Foerster LLP on

On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more

Sheppard Mullin Richter & Hampton LLP

Reminder to Perform Annual ISO/ESPP Reporting in January 2014

Sheppard Mullin Richter & Hampton LLP on

As discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require Employers to annually furnish each employee who exercised...more

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