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Capital Gains Tax Internal Revenue Service

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

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The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Kohrman Jackson & Krantz LLP

Navigating Section 1014 and the TCJA: A Deep Dive into the IRS Ruling on Basis Adjustments

Understanding the nuances of the Internal Revenue Code (I.R.C.) is crucial for effective estate planning and tax strategy. For example, estate planners must be familiar with the tax basis adjustment provisions in 26 U.S.C. §...more

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

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Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Allen Barron, Inc.

You Need to Review Your Irrevocable Trust

Allen Barron, Inc. on

Do you employ an irrevocable trust or trusts as part of your estate plan? You need to review your irrevocable trust to ensure it still delivers the benefits intended. It is generally possible to modify an irrevocable trust,...more

Venable LLP

Earnouts and Their Tax Treatment

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As buyers and sellers engage in negotiations for the sale of a business, often there may be disagreements as to the value and expected growth of that business. One party might currently value the business higher than the...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

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In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Davidoff Hutcher & Citron LLP

If It's Too Good To Be True...The Latest Guidelines from the IRS

There are a lot of very smart tax attorneys out there who are trying to figure out something new, and yet there’s very little innovation.  Almost all techniques that we use are incremental variations of an older technique...more

DarrowEverett LLP

1031 Exchanges and the Complexities of Seller Financing

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With interest rates nearly the highest they’ve been in decades, but property prices still high, sellers and buyers are looking for ways to finance real estate transactions while also availing themselves of IRC § 1031’s...more

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

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What are the most important elements of estate and tax planning for US expatriates?  Are you planning to move out of the United States?  Are you a US taxpayer who lives and works outside of the country?  What are some of the...more

Allen Barron, Inc.

Tax Tips for Lottery Winners

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Today is the anniversary of the largest Powerball lottery victory in the United States of $2.04 billion.  Just over the $1.765 billion jackpot claimed last month (Oct 2023).  What are some tax tips for lottery winners and...more

Blank Rome LLP

NFTs: A Tale of Two Classifications

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On March 21, 2023, the Department of the Treasury and the Internal Revenue Service (“IRS)” released Notice 2023-27, announcing their intent to provide guidance on classifying certain non-fungible tokens (“NFTs”) as...more

Bowditch & Dewey

Cryptocurrency Wash-Sale Loss Harvesting

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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

Seward & Kissel LLP

NFT Means Never Forget Taxes: Redux

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The Internal Revenue Service released Notice 2023-27 (the “Notice”), providing guidance on the federal tax treatment of nonfungible tokens (“NFTs”). In a prior SKRYPTO blogpost, we noted that investors selling NFTs could be...more

Foodman CPAs & Advisors

La Disminución Del Valor Cripto No Es Igual A La Deducción Fiscal Cripto

Dado que estamos en pleno apogeo de la temporada de impuestos, muchos contribuyentes están explorando la posibilidad de reclamar una deducción de impuestos cripto sobre sus activos cripto “devaluados”. Los contribuyentes...more

ASKramer Law

Can You Write Off Crypto Losses? IRS Says Intention Matters

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A taxpayer’s investment losses, including losses on digital assets such as cryptocurrencies and non-fungible tokens (NFTs), are not deductible unless the taxpayer’s activities rise to the level of “investment activities” or...more

ASKramer Law

IRS Takes a New Approach to NFT Taxes and ‘Collectibles’

ASKramer Law on

Until very recently, the IRS has been silent about the tax treatment of non-fungible tokens (NFTs). An almost unknown market in 2020, NFTs skyrocketed to prominence in 2021 with a capitalization at the beginning of 2021 of...more

Rivkin Radler LLP

Investor Beware: 1031 Exchanges Come with Legal Pitfalls

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Capital gains taxes can take a chunk out of the proceeds from an investment property sale – sometimes upward of 30% when federal and state taxes are combined. A 1031 tax deferred exchange is one way to defer paying capital...more

A&O Shearman

2022 Year End Estate Planning Advisory

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The current estate planning landscape is drastically different than it was at the beginning of this year. After an extended period of historically low rates of interest and inflation, this year the Federal Reserve began...more

Mintz - Energy & Sustainability Viewpoints

Summary of Important Tax Provisions Included in the Recently Announced Inflation Reduction Act of 2022

On July 27, 2022, Senator Joe Manchin and Senate Majority Leader Chuck Schumer announced that they have reached an agreement on a budget reconciliation bill (the Inflation Reduction Act of 2022, the “Act”). Although the Act...more

Bailey & Glasser, LLP

BG Tax Alert - Take Two: Biden’s Budget Proposes Tax Hikes

Bailey & Glasser, LLP on

On March 28, 2022, President Biden announced his 2023 federal budget (Budget), which is often referred to as the President’s Green Book. While much of the Budget harkens back to the “Build Back Better Framework” (Framework),...more

Jones & Keller, P.C.

Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller

Jones & Keller, P.C. on

High-net worth individuals have an opportunity to take advantage of high transfer tax exemptions if they act fast. Set to expire in 2026, unless Congress acts sooner, the time is now to implement strategies that make the most...more

Jones & Keller, P.C.

Taking the Sting Out of “Death Taxes”

Jones & Keller, P.C. on

There has been a lot of talk since September 2021 about the Build Back Better Act, which included some major tax increases. According to U.S. Senator Joe Manchin of West Virginia, this Act is dead—and I think that is the most...more

Lasher Holzapfel Sperry & Ebberson PLLC

Washington’s New Capital Gains Tax is Overturned as Unconstitutional

In 2021, Washington State Legislature passed ESSB 5096, which created a 7% tax on the sale or exchange of long-term capital assets (stocks, bonds, business interests, or other investments, and many tangible assets) if the...more

Freeman Law

Taxation of Crypto Mining

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Amid the crypto boom, mining has become an extremely lucrative venture for many and critical to maintaining decentralized cryptocurrency networks. It is no surprise then that mining has been subject to IRS scrutiny and...more

Freeman Law

Taxation of Crypto Margin Trading

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This year has been a banner year for cryptocurrencies, with the prices of Bitcoin and Ethereum reaching all-time highs in November. Undoubtably, margin trading – the borrowing of capital from a broker or a margin lender to...more

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