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Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

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The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

Rivkin Radler LLP

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

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Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

McDermott Will & Emery

Federal District Court Rules Codified Economic Substance Doctrine Vitiates Tax Transaction Benefits

McDermott Will & Emery on

On October 31, 2023, the US District Court for the District of Colorado, in Liberty Global, Inc. v. United States, applied the codified economic substance doctrine and held—on summary judgment—that Liberty Global, Inc. (LGI)...more

Allen Barron, Inc.

The US Treasury Department and IRS Have Released New Proposed Regulations on Sales and Exchanges of Digital Assets

Allen Barron, Inc. on

The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more

Foley & Lardner LLP

Opportunity Zones: Should Your Startup Make One Its Home?

Foley & Lardner LLP on

A Qualified Opportunity Zone (QOZ) is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. The U.S. federal government created this tax...more

Groom Law Group, Chartered

IRS Announces Intention to Issue Guidance on NFTs

On March 21, 2023, the Department of Treasury (“Treasury”) and Internal Revenue Service (“IRS”) released Notice 2023-27, which announced that Treasury and the IRS intend to issue guidance related to the treatment of certain...more

BakerHostetler

IRS Issues Guidance on Non-Fungible Tokens What It Says and Does Not Say

BakerHostetler on

The IRS and Treasury Department announced on March 21, 2023, that they intend to issue guidance providing that certain NFTs qualify as collectibles under Section 408(m) of the Code. The Notice is the first guidance issued by...more

Foley & Lardner LLP

IRS Issues Notice on Treatment of NFTs as Collectibles

Foley & Lardner LLP on

On March 21, 2023, the Internal Revenue Service (the IRS) released Notice 2023-27 (the Notice) announcing that the Treasury Department and the IRS intend to issue guidance related to the treatment of certain Non-Fungible...more

Morrison & Foerster LLP

Proposed “Inflation Reduction Act” Could Significantly Curtail Carried Interest Tax Benefits

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more

Paul Hastings LLP

Proposed Legislation Threatens to Upend Carried Interest Rules

Paul Hastings LLP on

As widely reported, on July 27, 2022 Democratic Majority Leader Senator Chuck Schumer and Senator Joe Manchin (D-W.Va) agreed to a reconciliation bill package titled the Inflation Reduction Act of 2022. The bill contains...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

McDermott Will & Emery

Weekly IRS Roundup October 11 – October 15, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 11, 2021 – October 15, 2021... October 12, 2021: The IRS released a notice, announcing...more

Rivkin Radler LLP

Bona Fide Intercompany Loan – Are You Sure?

Rivkin Radler LLP on

Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more

Rivkin Radler LLP

The Biden Administration’s Revenue Proposals For Fiscal Year 2022: Tax Increases And Forced Recognition Of Capital Gains

Rivkin Radler LLP on

Extra, Extra!- Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Williams Mullen

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

Williams Mullen on

The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

Latham & Watkins LLP on

While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Goodwin

Highlights From The Final Carried Interest Regulations

Goodwin on

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

Locke Lord LLP

IRS Issues Final Regulations on Partnership Carried Interests

Locke Lord LLP on

On January 13, 2021, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued the official version of Final Treasury Regulations (the “Final Regulations”) providing guidance under the “carried...more

Proskauer - Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

Proskauer - Tax Talks on

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more

Mintz - Real Estate, Construction &...

IRS Issues Final Regulations on Taxation of Carried Interest Under Section 1061

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more

Seyfarth Shaw LLP

US Treasury Proposes Regulations Addressing the New Holding Period for Partnership Profits Interests

Seyfarth Shaw LLP on

Seyfarth Synopsis: On July 31, 2020, the US Department of Treasury (“Treasury”) published long-awaited proposed Treasury regulations (the “Proposed Regulations”) that provide detailed guidance on the new Code Section enacted...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Goodwin

Highlights From The Proposed Carried Interest Regulations

Goodwin on

The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

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