On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more
5/21/2024
/ Covered Entities ,
Debt ,
Excise Tax ,
Fair Market Value ,
Foreign Corporations ,
IRS ,
Payment Systems ,
Proposed Regulation ,
Reorganizations ,
Reporting Requirements ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Repurchases ,
Stocks ,
U.S. Treasury
On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more
3/28/2024
/ Base Erosion and Anti-Abuse Tax (BEAT) ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Digital Assets ,
Excise Tax ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Green Book ,
Liquidation ,
NIIT ,
Property Tax ,
Tax Policy ,
Tax Reform
This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect to the taxation of digital...more
5/2/2023
/ Biden Administration ,
Brokers ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Digital Assets ,
Excise Tax ,
FATCA ,
Green Book ,
Infrastructure Investment and Jobs Act (IIJA) ,
IRS ,
New Guidance ,
Non-Fungible Tokens (NFTs) ,
Proposed Legislation ,
Reporting Requirements ,
Stablecoins ,
Virtual Currency
On August 16, 2022 President Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law.
The IRA includes a 15% corporate alternative minimum tax, a 1% excise tax on stock buybacks and a two-year extension of...more
On August 7, the Senate passed the Inflation Reduction Act of 2022 (the “IRA”). The tax provisions in the bill that was passed vary from the bill that was originally released on July 27, 2022 by Senator Joe Manchin (D-W.Va.)...more