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Paul Hastings LLP

Crypto Tax Update – April 2025

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In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more

McDermott Will & Emery

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

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Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more

Groom Law Group, Chartered

IRS Provides Tax Guidance Related to State-Run Paid Family and Medical Leave Programs

On January 16, 2025, the Internal Revenue Service (“IRS”) issued Revenue Ruling 2025-4 (the “Rev. Rul.”). The Rev. Rul. provides guidance on the federal tax treatment of contributions to and benefits paid under a state paid...more

Dorsey & Whitney LLP

Certain Canadian Corporations May Unknowingly be Subject to U.S. Federal Backup Withholding and Reporting Requirements With...

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Canadian corporations making dividend payments should ensure that they are compliant with U.S. federal backup withholding and reporting requirements to avoid potential U.S. federal income tax issues....more

Foodman CPAs & Advisors

FATCA Responsible Officer Certifications due 7/1/25

On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

Baker Donelson on

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

Groom Law Group, Chartered

New Year, New ACA Penalty and Reporting Relief!

In late December, President Biden signed into law relief related to Code section 4980H employer mandate penalties and Code section 6055 minimum essential coverage (“MEC”) and Code section 6056 employer mandate reporting on...more

The Wagner Law Group

IRS Issues Final Regulations on Non-U.S. Tax Withholding Under Deferred Compensation Plans, IRAs and Commercial Annuities

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The Internal Revenue Service (“IRS”) and the Treasury Department on October 21, 2024, issued final regulations under Sections 3405(a) and 3405(b) of the Internal Revenue Code of 1986, as amended (“Code”). (The IRS had issued...more

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Takes Aim at Basis Adjustments in Partnership Transactions

On June 17, 2024, the IRS issued three pieces of guidance addressing certain “basis-shifting” transactions in the context of related-party partnerships: In new proposed regulations, the IRS identified several...more

McDermott Will & Emery

Weekly IRS Roundup March 25 – March 29, 2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25, 2024 – March 29, 2024....more

Pillsbury Winthrop Shaw Pittman LLP

Treasury Department and IRS Issue Final Regulations and Other Guidance on the Direct Pay Election under Section 6417 of the...

Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more

Skadden, Arps, Slate, Meagher & Flom LLP

Observations on Notice 2023-80: The Treasury Department and IRS’ Preliminary Guidance on the Interaction of Foreign Tax Credit and...

On December 11, 2023, the Department of the Treasury (the Treasury Department) and the Internal Revenue Service (IRS) released much-anticipated guidance in Notice 2023-80 (Notice) announcing their intention to issue proposed...more

Fenwick & West LLP

Fenwick Writes Comment Letter on Notice 2023-63 on Amortization of Specified Research or Experimental Expenditures under Section...

Fenwick & West LLP on

Following the IRS’s issuance of guidance in Notice 2023-63 regarding R&D capitalization under Section 174, a working group of several Fenwick tax group attorneys commented to the IRS and the U.S. Treasury Department on...more

Ward and Smith, P.A.

Mo Money, Mo Problems? No Biggie for a Homeowner's Association, Right?

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Was your community association lucky enough to come in under budget last year? On the surface, this might appear to be a bonus, but if not handled properly, it can quickly turn into an unexpected tax burden. ...more

McGlinchey Stafford

When Are My Rewards for Staking Cryptocurrency Taxed?

McGlinchey Stafford on

The IRS recently released Revenue Ruling 2023-14, in which it addresses the tax treatment of cryptocurrency staking rewards. The IRS phases the issue as follows: If a taxpayer that uses a cash method of accounting...more

McDermott Will & Emery

Weekly IRS Roundup June 20 – June 23, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the shortened week of June 20, 2023 – June 23, 2023. (June 19 is a federal holiday.)...more

King & Spalding

Proposed Regulations Would Impact Taxation of Investment in U.S. Real Estate by Non-U.S. Investors

King & Spalding on

On December 29, 2022, the IRS and Treasury issued proposed regulations (the “Proposed Regulations”) addressing (1) whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute...more

McDermott Will & Emery

Jarrett Leaves Unanswered Questions on Taxation of Staking Rewards

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In the latest turn of events for the closely followed Jarrett case concerning the taxation of staking rewards, on September 30, 2022, the US District Court for the Middle District of Tennessee granted the United States’...more

Gerald Nowotny - Law Office of Gerald R....

All in the Family – Introducing Family-Owned Life Insurance™ (aka FOLI)

Perhaps you are tired of reading that I grew up in the Panama Canal Zone, but it is one of the last bastions of American colonialism. Personally, I do not like the word “colonialism” because it inevitably conjures up negative...more

McDermott Will & Emery

Key Digital Asset Tax Proposals in the Biden Administration's Green Book

On March 28, 2022, the US Department of the Treasury released the Fiscal Year (FY) 2023 Revenue Proposals and Green Book, which describes the tax proposals in the Biden administration’s FY 2023 budget (2023 Budget Proposal)....more

Flaster Greenberg PC

Digital, Digital Break Down: How to Make Sure You’re *NSYNC with IRS Changes for Reporting Virtual Payment Transactions

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You may have seen recent headlines warning that the IRS is tracking certain transactions paid using digital payment services such as Paypal, Cash App, Zelle, and Venmo. Even worse, you may have wondered whether a new law...more

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