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Income Taxes › Internal Revenue Service › Fair Market Value

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
McGlinchey Stafford

Legislation: Cryptocurrency Staking Rewards Taxed at Time of Sale

McGlinchey Stafford on

Proposed federal legislation would move the time of taxation for rewards received from staking cryptocurrency and other digital assets to the time of sale. IRS guidance currently provides that staking rewards are taxed at the...more

Holland & Knight LLP

Not So Cryptic: IRS Increases Oversight on Cryptocurrency Income Tax Reporting Requirements

Holland & Knight LLP on

Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Troutman Pepper

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations

Troutman Pepper on

Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more

Adler Pollock & Sheehan P.C.

Should You Place Your Home in a QPRT?

Adler Pollock & Sheehan P.C. on

If you own your principal residence, you may be able to benefit from its build-up in equity, realize current tax breaks and pocket a sizeable tax-exempt gain when you sell it. What’s more, from an estate planning perspective,...more

Cadwalader, Wickersham & Taft LLP

IRS Holds That Crypto Staking Rewards are Taxable Income

Cadwalader, Wickersham & Taft LLP on

The Internal Revenue Service (“IRS”) recently issued guidance in Revenue Ruling 2023-14, holding that taxpayers who stake their cryptocurrency and receive additional units of cryptocurrency as rewards when validation occurs...more

Rivkin Radler LLP

Sale of Mortgaged Property – Amount Realized or COD Income

Rivkin Radler LLP on

Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more

Seward & Kissel LLP

IRS Raises the Stakes on Staking

Seward & Kissel LLP on

The IRS published guidance on the federal income tax treatment of staking income in Revenue Ruling 2023-14.  Consistent with its prior ruling on hard forks, the IRS maintains that taxpayers realize taxable income when he or...more

McDermott Will & Emery

IRS Guidance Declares That Taxpayers Must Include Staking Rewards in Gross Income

McDermott Will & Emery on

On July 31, 2023, the Internal Revenue Service (IRS) released Revenue Ruling 2023-14, which concludes that the fair market value of staking rewards received by a cash-method taxpayer is includible in the taxpayer’s gross...more

Bowditch & Dewey

Starting a Start-Up? Here’s One More Thing You Need to Know: The 83(b) Election

Bowditch & Dewey on

Many people are forming start-up entities, especially in the Boston and Worcester areas, and for some, it becomes a great success story. For others, it does not. As an attorney who assists many start-ups and investors, I see...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

Rivkin Radler LLP on

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Freeman Law

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

Freeman Law on

Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more

Snell & Wilmer

Taxation of Cryptocurrency and Similar Transactions

Snell & Wilmer on

Whether you’re an investor expanding your portfolio to include digital assets such as cryptocurrencies and tokens, a business that uses cryptocurrencies to engage in everyday transactions, or a crypto “miner," you need to...more

Rivkin Radler LLP

Not Selling Despite Tax Increases? Review the Buy-Sell Agreement Among Owners

Rivkin Radler LLP on

Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more

Chambliss, Bahner & Stophel, P.C.

Tax Implications of House Passage of the Build Back Better Act

Chambliss, Bahner & Stophel, P.C. on

This morning, the House of Representatives voted 220 to 213 in favor of passing the Build Back Better Act (the Bill). The Congressional Budget Office estimates the bill will cost almost $1.7 trillion and add $367 billion to...more

Proskauer Rose LLP

Wealth Management Update - August 2021

Proskauer Rose LLP on

Federal interest rates were largely stable in August of 2021.The August applicable federal rate ("AFR") for use with a sale to a defective grantor trust, self-canceling installment note ("SCIN") or intra-family loan with a...more

Smith Gambrell Russell

Tax Trial of the Century…

Smith Gambrell Russell on

Which does not belong: Bad, Thriller, Moonwalk, Tax Court. Actually it is not a fair question because they all have one thing in common, Michael Jackson. The last one being the Estate of Michael J. Jackson v. Commissioner...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

Rivkin Radler LLP on

Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

Rivkin Radler LLP on

Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Farrell Fritz, P.C.

Out Of New York, But Still Being Taxed By New York? Look To The Source

Farrell Fritz, P.C. on

New York Diaspora? Like most every other state in the Union, New York has experienced its share of fiscal stress over the last few decades. The source or cause of its problems? Well, that may depend upon the respondent to...more

Fenwick & West LLP

PFIC: What U.S. Investment Funds Should be Particularly Aware of and Newly Proposed Regulations

Fenwick & West LLP on

U.S.-based venture capital and other funds that invest in foreign companies must be careful to avoid the passive foreign investment company (PFIC) rules, which could substantially increase the tax owed on exit for U.S....more

Proskauer - Tax Talks

IRS answers some, but not all, questions in long-awaited cryptocurrency guidance

Proskauer - Tax Talks on

The first official guidance on the taxation of cryptocurrency transactions in more than five years has been issued. The guidance includes both a Revenue Ruling (Rev. Rul. 2019-24, 2019-44 I.R.B. 1) and answers to...more

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