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New IRS Guidance Provides a Spot of Certainty Amid Digital Asset Limbo

Per recent transitional guidance, the IRS will not require taxpayers to report transactions involving receipt of digital assets under Section 6050I....more

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

Athletes, Artists, and Audits: IRS Renews Focus on High-Wealth Individuals and Associated Entities

The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts sports owners, athletes, entertainers, and others in these industries to the...more

IRS Releases Tax Return Amendment Relief for BBA Partnerships

The Internal Revenue Service has released guidance allowing partnerships subject to amended return filing restrictions enacted under the Bipartisan Budget Act of 2015 to amend 2018 and 2019 partnership returns, including in...more

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