The Supreme Court confirmed in Centrica Overseas Holdings Ltd v HMRC that the tests for trading and management expenses of a capital nature are the same. The decision also confirms that once a company has decided in principle...more
The IRS wash-sale rule does not currently apply to cryptocurrency because the IRS considers virtual currencies to be property rather than securities. In general, a taxpayer who exchanges cryptocurrency for goods, services or...more
As we move into the final quarter of 2022, it is critical to take note of an expiring tax benefit in the Tax Cuts and Jobs Act (TCJA). Passed in 2017, it allows for 100% bonus depreciation on a wide variety of capital assets...more
Deal Costs, Generally- Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more
Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue...more
The “Tax Cuts and Jobs Act of 2017” (the “TCJA”) impact on the tax treatment of self-created intellectual property (“IP”) is resulting in a wide range of feelings depending on the nature of a particular party’s IP. Contrast...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more