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Internal Revenue Code (IRC) Fair Market Value Income Taxes

Snell & Wilmer

IRS Releases Standardized Section 83(b) Election

Snell & Wilmer on

As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more

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

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

Foley & Lardner LLP on

This article is the third 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

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

King & Spalding on

On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper Locke on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Bowditch & Dewey

Starting a Start-Up? Here’s One More Thing You Need to Know: The 83(b) Election

Bowditch & Dewey on

Many people are forming start-up entities, especially in the Boston and Worcester areas, and for some, it becomes a great success story. For others, it does not. As an attorney who assists many start-ups and investors, I see...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

Rivkin Radler LLP on

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Freeman Law

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

Freeman Law on

Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more

Coblentz Patch Duffy & Bass

2020 Tax Planning: Benefits of GRATs

Now may be an opportune time to gift assets out of your estate, particularly through an estate planning technique known as the Grantor Retained Annuity Trust (“GRAT“)—a small silver lining of the alarming pandemic and down...more

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