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Capital Gains Tax Tax Planning

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part X – Converting a...

Foster Garvey PC on

When considering converting a C corporation to an S corporation, tax advisers and taxpayers need to pay careful attention to the many perils that exist. Failure to pay close attention to the road in this area could result in...more

Cadwalader, Wickersham & Taft LLP

An option to dispose of property does not necessarily give rise to a taxable disposal

In the appeal case of Krishnamohan v HMRC [2024] UKFTT 346, the UK’s First-Tier Tribunal (“FTT”) determined that an agreement titled “Option Agreement” that was entered into to dispose of certain properties, does not, for...more

Proskauer - Tax Talks

Change to non-domicile tax regime forms part of UK Spring Budget 2024

Proskauer - Tax Talks on

As part of the UK’s Spring Budget 2024, the Chancellor of the Exchequer, Jeremy Hunt, has announced the abolition of the remittance basis for income tax and capital gains tax for non-UK domiciled, UK resident individuals (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

Allen Barron, Inc.

Estate and Tax Planning for US Expatriates

Allen Barron, Inc. on

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

Partridge Snow & Hahn LLP

Gifts of Privately Held Company Interests to a 501(c)(3) Public Charity

Donors with ownership interests in privately held companies (i.e., limited liability companies, corporations, partnerships) have the ability to utilize the interest to make a charitable gift. This strategy becomes...more

Davidoff Hutcher & Citron LLP

Unsure of Stepped-Up Basis? Here is a 5-Point Primer

Stepped-up basis is a tax law that applies to estate transfers when a person receives an asset from a giver after a benefactor passes away. In those circumstances, the asset receives a “stepped-up” basis – which is the market...more

Bowditch & Dewey

Cryptocurrency Wash-Sale Loss Harvesting

Bowditch & Dewey on

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

Brownstein Hyatt Farber Schreck

House Republicans Introduce Expansive Tax-Reform Package: The American Families and Jobs Act

House Ways and Means Committee Chairman Jason Smith (R-MO) unveiled committee Republicans’ economic-growth package on June 9, introducing three individual bills that encompass tax provisions relevant to a broad cross-section...more

K&L Gates LLP

New Washington Capital Gains Tax Impacts Estate Planning

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The Washington Supreme Court recently upheld as constitutional the state’s capital gains tax (WA Cap Gains Tax) that was enacted in 2021. The new WA Cap Gains Tax creates new wrinkles and provides new planning opportunities...more

Miller Nash LLP

Washington’s New Capital Gains Excise Tax: An Income Tax by Another Name

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The Washington State Supreme Court recently upheld an excise tax on the privilege of selling capital assets within the State of Washington. The Court upheld the new tax over concerns that the tax violated both the state and...more

Stoel Rives LLP

Washington Supreme Court Upholds Capital Gains Tax

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Effective January 1, 2022, Washington law imposes a 7% tax on gains over $250,000 per year from the sale or exchange of long-term capital assets allocated to Washington such as stocks, bonds, business interests, or other...more

Cadwalader, Wickersham & Taft LLP

Potential Constitutional Challenge: Biden Budget Proposes Mark-to-Market for High-Net-Worth Individuals

In President Biden’s State of the Union address, he called on all Americans to pay their “fair share.” The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals contains several...more

Brownstein Hyatt Farber Schreck

Ways and Means Chair Jason Smith’s Potential Legislative Agenda

Following two rounds of votes, the House Republican Steering Committee elected Rep. Jason Smith (R-MO) to serve as the chair of the House Ways and Means Committee for the 118th Congress. Smith has served on the committee...more

Morgan Lewis

Planning for the Massachusetts ‘Millionaires Tax’

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The new Massachusetts “Millionaires Tax” imposes an additional 4% income tax on the portion of annual taxable income in excess of $1 million (indexed for inflation), starting in 2023. The new tax will affect high-income...more

A&O Shearman

2022 Year End Estate Planning Advisory

A&O Shearman on

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

Katten Muchin Rosenman LLP

Greener Pastures: Five Things to Consider When Leaving One Jurisdiction for Another

Is the grass always greener on the other side? Like any major life decision, deciding to uproot yourself (and potentially your family) and move from one state to another is not an easy decision. Although laws, taxes and...more

A&O Shearman

Volatile Reaction to UK “Mini-Budget”

A&O Shearman on

Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...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

Hogan Lovells

Recent changes to the UAE legal landscape: March 2022

Hogan Lovells on

The United Arab Emirates (UAE), which has made significant updates to its laws governing commercial activity in recent years, has again revised and refined the statutory landscape for companies in the country. The issuance of...more

Ward and Smith, P.A.

Rapid Fire Legal Update on Tax Provisions, E-Discovery, Lobbying Issues, and ADA Compliance

Ward and Smith, P.A. on

We recently provided timely updates on new tax provisions, electronic discovery, lobbying issues, and ADA compliance during Ward and Smith's 2021 Virtual In-House Counsel Webinar. The following article highlights...more

Freeman Law

Taxation of Crypto Margin Trading

Freeman Law on

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

Freeman Law

The Tax Implications of DeFi: A General Overview

Freeman Law on

DeFi, or decentralized finance, has experienced unprecedented growth over the last few years, resulting in a market cap of approximately $85 billion as of October 2021. Built on blockchain technology and cryptocurrency, DeFi...more

Polsinelli

The Proposed Build Back Better Act Moves Forward After the House Passes a Revised Version of the Bill

Polsinelli on

Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more

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