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Tax Reform Capital Gains

Lippes Mathias LLP

Canada’s Capital Gains Tax and the Exodus to the U.S.

Lippes Mathias LLP on

There may be a change coming to the way Canada taxes capital gains. While Prime Minister Justin Trudeau claims it will affect a minuscule percentage of Canadians, it has more than a minuscule percentage of Canadian taxpayers...more

McDermott Will & Emery

UK Labour Party's Statement on Non-Dom Tax Reforms

McDermott Will & Emery on

Following the UK Government’s 6 March announcement of tax reforms for the current “non-dom” tax regimes, the opposition Labour party has begun to outline how its plans would differ if they win the next UK general election. In...more

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

Whiteford on

In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

Proskauer - Tax Talks on

As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (the...more

Goodwin

Massachusetts Doubles Estate Tax Exemption as Part of $1 Billion Tax Bill

Goodwin on

Massachusetts has passed a sweeping $1 billion tax relief package intended to boost the Commonwealth’s affordability and competitiveness. Among other changes, the tax bill doubles the Massachusetts estate tax exemption to $2...more

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

Proskauer - Tax Talks

Proskauer Tax Talks: Green Book 2024

Proskauer - Tax Talks on

On March 9, 2023, the Biden Administration released the Fiscal Year 2024 Budget, and the “General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more

Bennett Jones LLP

The Alternative Minimum Tax Goes Mainstream

Bennett Jones LLP on

The 2023 Budget proposes material changes to the alternative minimum tax (AMT) regime which, as discussed below, could result in significant increases to taxes on capital gains (i.e.,5-6 percentage points). Although...more

Cadwalader, Wickersham & Taft LLP

UK Budget 2023 – Key Tax Measures

The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2023 on 15 March 2023. The Budget was delivered against a backdrop of some familiar political headwinds, caused by the lengthy shockwaves of...more

Burr & Forman

Changes in Tax Rates for 2023

Burr & Forman on

The IRS has issued Revenue Procedure 2022-38, which sets forth inflation-adjusted items for various provisions of the Internal Revenue Code which will be applicable in 2023. Here are some of the highlights...more

ArentFox Schiff

Key Tax Changes Impacting Businesses in the New Inflation Reduction Act

ArentFox Schiff on

Today, President Joe Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). Although the proposal further restricting the availability of long-term capital gain treatment with respect to carried interests...more

Dechert LLP

Another Stab at Carried Interests Under the Inflation Reduction Act of 2022

Dechert LLP on

On July 27, 2022, Senator Joe Manchin III (D-W.Va.) and Majority Leader Charles E. Schumer (D-N.Y.) introduced legislation entitled the “Inflation Reduction Act of 2022” (the “Reconciliation Bill”). The Reconciliation Bill is...more

Goulston & Storrs PC

New Bill Will Tax Real Estate “Promote” as Carried Interest Subject to Three-Year Holding Period

Goulston & Storrs PC on

Senators Manchin and Schumer this week announced that the “Inflation Reduction Act of 2022” will be added to the FY2022 Budget Reconciliation bill. The bill includes changes to Section 1061 of the Code (which was added to the...more

Cadwalader, Wickersham & Taft LLP

A Pocket Guide to the 2023 Budget Proposals

On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Goulston & Storrs PC

Biden’s FY2023 Budget: Key Real Estate & Corporate Tax Proposals

Goulston & Storrs PC on

On March 28, 2022, President Biden released his FY2023 budget (the “FY2023 Budget”), and the U.S. Treasury released the so-called “Green Book,” which provides details related to the revenue provisions in the FY2023 Budget....more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022

Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more

Dechert LLP

Cryptocurrency Stakeholders Should Prepare for Increased Tax Enforcement

Dechert LLP on

As we recently noted in our OnPoint dated October 20, 2021, the rise in interest from retail and institutional investors in the cryptocurrency market has attracted increased regulatory and enforcement attention in the past...more

Foodman CPAs & Advisors

IRS Puts Brokers On The Hot Seat for Crypto Tax Reporting

Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more

Cadwalader, Wickersham & Taft LLP

Keep Your Eyes on Mark-to-Market

We report elsewhere in this issue on Senate Finance Committee Chair Ron Wyden's (D-Ore.) proposed mark-to-market tax on billionaires. On August 5, 2021, Wyden also introduced the Modernization of Derivatives Tax Act of 2021...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...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

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

Mintz - ML Strategies on

In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

Foley & Lardner LLP

Build Back Better Tax Proposals: Considerations for Private Investment Funds & Sponsors

Foley & Lardner LLP on

On September 13, 2021, the House of Representative Ways and Means Committee introduced tax proposals that, if enacted, would make significant changes to the U.S. federal income tax system. This Alert summarizes some of the...more

Verrill

House Democrats Propose Estate and Gift Tax Law Changes: Important Estate Planning Implications

Verrill on

What you need to know: On September 13, 2021, the House Ways and Means Committee released its proposed tax plan to fund President Biden’s $3.5 trillion “Build Back Better” social and economic spending package. If enacted as...more

Cozen O'Connor

House Ways and Means Committee Proposes Reduction of QSBS Exclusion

Cozen O'Connor on

On September 15, 2021, the House Ways and Means Committee approved its draft tax legislation that was released on September 13, 2021, as part of the “Build Back Better” budget reconciliation program. Included in the draft...more

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