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Income Taxes › 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 -
Pillsbury - Propel

Equity Compensation: Navigating 409A Valuations

Pillsbury - Propel on

Private company clients frequently ask us about granting compensatory stock options to their founders, employees and other service providers, including board members, consultants and advisors. Options and other equity awards...more

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

Mayer Brown on

Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Allen Barron, Inc.

The Step Up Benefit of a Revocable Trust

Allen Barron, Inc. on

What is the step-up benefit of a revocable trust from the perspective of the beneficiaries? How can a revocable trust not only pass money and assets to your beneficiaries but save a substantial amount of tax in the process? ...more

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: Basics of Nonqualified Stock Options and Stock-Settled Stock...

Foley & Lardner LLP on

This article is the second in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...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

Rivkin Radler LLP

Withholding Taxes: Deferred Comp and Services Overseas

Rivkin Radler LLP on

Approaching Year End- Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than...more

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

Holland & Knight LLP

En Colombia Consejo de Estado precisa tratamiento tributario de dividendos para régimen SIMPLE

Holland & Knight LLP on

Proferida dentro del expediente #26084 en sentencia de 10 de noviembre de 2022, al analizar la legalidad del artículo 3 del Decreto 1457 del 12 de noviembre de 2020, que regula el tratamiento de los dividendos y...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

Rivkin Radler LLP

The Tax-Deferred Rollover – Some Considerations

Rivkin Radler LLP on

“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan- That line probably describes the exasperation with which many Americans...more

Jones Day

Employee Stock Plans: International Reporting Requirements

Jones Day on

This White Paper highlights some of the principal annual reporting requirements for employee stock plans that multinational companies most commonly encounter when offering these programs to their employees in selected...more

Farella Braun + Martel LLP

Estate Tax Planning for Large Company Stock Holdings: Four Tips for Using Record-High Lifetime Exemptions

Farella Braun + Martel LLP on

- Annual inflation-indexing continues to increase the historically high lifetime exemption amount for gift, estate, and generation-skipping transfer taxes. Those of considerable wealth who have not yet made gifts, such as...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

Downey Brand LLP

Valuation Discounts in Modern Estate Planning

Downey Brand LLP on

For most family business owners, the old way of discount planning has become perishable. For many years, closely-held business owners routinely heard estate planners advise them to give or sometimes sell family members’...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

Davis Wright Tremaine LLP

Donate Publicly Traded Stock to Charity Instead of Cash

Davis Wright Tremaine LLP on

Due to the general success of the stock market in recent times, many people are currently carrying appreciated stock as part of their balance sheet. Individuals who are charitably inclined and looking to make donations to a...more

Morgan Lewis

New US Tax Law Provides Tax Deferral Opportunity for Certain Private Company Equity Grants

Morgan Lewis on

The adoption of Internal Revenue Code Section 83(i) under recent US tax reform will allow certain private company employees to defer federal income tax on eligible stock options and restricted stock units for up to five years...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

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